ML21032A115

Global Nuclear Fuel-Americas, LLC-Nuclear Regulatory Commission Integrated Inspection Report 07001113/2020004

ML21032A115
Person / Time
Site:	07001113
Issue date:	01/29/2021
From:	Robert Williams NRC/RGN-II/DFFI
To:	Beard B Global Nuclear Fuel - Americas
References
IR 2020004
Download: ML21032A115 (27)

Text

January 29, 2021 Mr. Brad Beard Plant Leader Global Nuclear Fuel-Americas, L.L.C.

P.O. Box 780, Mail Code J20 Wilmington, NC 28402

SUBJECT:

GLOBAL NUCLEAR FUEL- AMERICAS, L.L.C. - NUCLEAR REGULATORY COMMISSION INTEGRATED INSPECTION REPORT 70-1113/2020-004

Dear Mr. Beard:

The Nuclear Regulatory Commission (NRC) conducted inspections during the fourth quarter of calendar year 2020 (October 1 - December 31, 2020), of the Global Nuclear Fuel-Americas, L.L.C. (GNF-A) facility in Wilmington, NC. During this period, the NRC implemented alternative methods to complete the core inspection program for your facility when routine onsite inspections could not be performed due to the public health emergency declared by the Secretary of Health and Human Services on January 31, 2020 (as renewed on April 21, 2020 and July 23, 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 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. The inspectors reviewed activities authorized under the license in the areas of safety operations, radiological controls, and facility support to determine whether they were conducted safely and in accordance with NRC requirements. At the conclusion of these inspections, the inspectors discussed the results with you and members of your staff at various exit meetings held throughout the quarter.

Based on the results of these 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 chances to the Integrated Safety Analysis Summary) and increased communications with your staff to discuss the status of plant operation.

B. Beard 2 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.

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 plans to continue to 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.

Should you have any questions concerning the results, please contact Leonard Pitts of my staff at 404-997-4708.

Sincerely,

/RA/

Robert E. Williams Jr., Chief Projects Branch 1 Division of Fuel Facility Inspection Docket No. 70-1113 License No. SNM-1097

Enclosure:

NRC Inspection Report 70-1113/2020-004 w/

Attachment:

Supplementary Information cc w/ encl: Distribution via LISTSERV

ML21032A115 SUNSI REVIEW COMPLETE FORM 665 ATTACHED OFFICE RII:DFFI/PB1 RII:DFFI/PB1 RII:DFFI/PB1 RII:DFFI/PB1 RII:DFFI/PB2 NAME L. Pitts M. Ruffin R. Williams L. Cooke P. Startz DATE 1/27/2021 1/26/2021 1/27/2021 1/27/2020 1/27/2021 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO OFFICE RII:DFFI/PB2 RII:DFFI/PB2 RII:DFFI/PB1 RII:DFFI/PB2 RII:DFFI/PB1 NAME G. Goff T. Sippel J. Ortiz-Rivera N. Peterka D. Edwards DATE 1/26/2021 1/27/2021 1/27/2021 1/27/2021 1/27/2021 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO U. S. NUCLEAR REGULATORY COMMISSION REGION II INSPECTION REPORT Docket No.: 70-1113 License No.: SNM-1097 Report No.: 70-1113/2020-004 Enterprise Identifier: I-2020-004-0067 Licensee: Global Nuclear Fuel - Americas, LLC Facility: Global Nuclear Fuel - Americas Location: Wilmington, North Carolina 28402 Dates: October 1, 2020 to December 31, 2020 Inspectors: L. Cooke, Fuel Facility Inspector (Section B.1, B.2, B.3)

D. Edwards, Fuel Facility Inspector (Section C.3)

G. Goff, Fuel Facility Inspector (Section C. 1)

N. Peterka, Fuel Facility Inspector (Section C.3)

J. Rivera-Ortiz, Senior Fuel Facility Inspection (Section A.2, D.1)

M. Ruffin, Fuel Facility Inspector (Section A.3, C.2, D.1)

T. Sippel, Fuel Facility Inspector (Section A.1)

P. Startz, Fuel Facility Inspector (Section C.3)

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

EXECUTIVE

SUMMARY

Global Nuclear Fuel - Americas, LLC Nuclear Regulatory Commission Integrated Inspection Report 70-1113/2020-004 October 1 - December 31, 2020 Nuclear Regulatory Commission regional inspectors conducted onsite inspections during normal shifts. These announced, routine inspections consisted of a selective examination of licensee activities accomplished by direct observation of safety-significant activities and equipment, a review of facility records and procedures and conducting interviews and discussions with licensee personnel. There were no violations of more than minor significance identified during these inspections.

Safety Operations

• In the area of Nuclear Criticality Safety, no violations of more than minor significance were identified. (Section A.1)

• In the area of Operational Safety, no violations of more-than-minor significance were identified in the area of Operational Safety. (Section A.2)

• In the area of Fire Protection, no violations of more than minor significance were identified.

(Section A.3)

Radiological Controls

• In the area of Radiation Protection, no violations of more than minor significance were identified. (Section B.1)

• In the area of Radioactive Waste Processing, Handling, Storage, and Transportation, no violations of more than minor significance were identified. (Section B.2)

• In the area of Effluent Control and Environmental Protection, no violations of more than minor significance were identified. (Section B.3)

Facility Support

• In the area of Maintenance and Surveillance of Safety Controls, no violations of more than minor significance were identified. (Section C.1)

• In the area of Emergency Preparedness, no violations of more than minor significance were identified. (Section C.2)

• In the area of Plant Modifications, no violations of more than minor significance were identified. (Section C.3)

Other Areas

• (Closed) Confirmatory Order Section V, Item 8, GNF-A supervisors engaged in licensed facility activities will complete initial Front Line Supervisor Nuclear Safety Leadership training and for a period of three years after issuance of the Confirmatory Order, new frontline supervisors engaged in licensed facility activities shall complete the training within six months of assuming supervisory responsibilities. (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 Global Nuclear Fuel - Americas (GNF-A), LLC manufactures uranium dioxide (UO2) powder, pellets, and light water reactor fuel bundles at its Wilmington, NC facility. The facility converts uranium hexafluoride (UF6) to UO2 using a Dry Conversion Process (DCP) and performs fuel fabrication operations. During the inspections, normal production activities at the facility were ongoing.

A. Safety Operations

1. 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 Title 10 of the Code of Federal Regulations, Part 70 (10 CFR 70), including 70.24, 70.61(d), 70.62(d),

Chapter 5 of the facilitys license application, Nuclear Criticality Safety, and applicable licensee procedures.

The inspectors reviewed selected criticality safety analyses (CSAs) to verify they were consistent with the commitments in the license application. These commitments included a commitment to assure that under normal and credible abnormal conditions, all fissile uranium processes remain subcritical, and maintain an adequate margin of safety; a commitment to establish and maintain NCS items relied on for safety (IROFS) based on current NCS determinations; and the commitment to the double contingency principle in Section 5.1.1 of the license application. The inspectors also reviewed the selected CSAs to determine whether calculations were performed within their validated areas of applicability and consistent with the validation report. The CSAs reviewed focused on those applicable to the UO2 Grinder area and 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 the assumptions made for upset conditions to verify they were appropriately conservative and matched the calculation input files. The inspectors also reviewed the protection and prevention scores assigned in the accident sequences to determine whether they were consistent with license requirements and resulted in the scenario being highly unlikely. This review was conducted for the UO2 Grinder area.

The inspectors verified that no changes were made to the validation report since the last NCS inspection.

Criticality Implementation 3

The inspectors performed walk downs of the Vaporization and UO2 Grinder areas to determine whether existing plant configuration and operations were covered by, and consistent with, the process descriptions and safety bases in the selected CSAs.

The inspectors reviewed IROFS training documents (i.e., TD 406-05, 406-13) and observed the controls in the field to verify engineered controls established in the CSAs were being implemented as specified. The engineered controls reviewed included, 406-01, 406-03, 406-04, 406-05, 406-13 and 505-09. The inspectors interviewed operators and engineers to verify administrative actions associated with these controls were understood and implemented as specified. The inspectors reviewed Quantitative Risk Assessment (QRA) 406/505, Fabrication - Grind, to determine whether the selected controls identified in the QRA were supported by technical bases in the CSAs.

Criticality Operational Oversight The inspectors reviewed NCS-related training material, including tests, to determine whether operator training included instruction in criticality hazards and control methods, whether the licensees established NCS-related operator training was consistent with commitments in Sections 2.2.1.6 and 2.3 of the license application, and whether NCS staff was involved in the development of operator training, as required.

Additionally, the inspectors interviewed NCS staff to determine how they were involved in the development of NCS training. The NCS-related training material reviewed included Radiation Worker Safety Criticality Safety, October 2019, and associated tests.

The inspectors reviewed records of NCS audits and accompanied a licensee NCS engineer on a surveillance of passive IROFS barriers to determine whether NCS staff routinely assessed field compliance with established NCS controls. Additionally, the inspectors interviewed NCS engineers and management and reviewed procedures to verify the NCS function audits were conducted as required by Section 11.6.1 of the license application, Criticality, Radiation, Chemical and Fire Safety Audits. The NCS audit records reviewed were for the third quarter of 2020, including 3Q 2020 Nuclear Safety Audit - UO2 Grind, Gad Grind, UO2 Rod Load, Gad Rod Load, Final Weld, UO2 Pellet Storage, Gad Pellet Storage, Cut-off Lathe, Off-line Sort, Rod Storage, dated September 25, 2020, and 3Q 2020 Nuclear Safety Audit - Engineering, Chemet and Environmental Labs, dated September 28, 2020. The inspectors reviewed these audit reports to verify that findings identified during these audits were entered into the corrective action program (CAP) in accordance with license application Section 11.6.1, and 5.3.2.2, Auditing, Assessing, and Upgrading the NCS Program.

Criticality Programmatic Oversight The inspectors reviewed recently revised NCS program procedures to determine whether the licensee implemented license requirements and whether the NCS program was enacted in accordance with them. The new and/or revised NCS program procedures included, WI-27-104-15, NCS Calculational Methods and Verification, Revision (Rev.) 3, dated March 6, 2020. The inspectors reviewed select CSAs listed in Section 4 of the attachment to verify they were performed in accordance with NCS program procedures and received appropriate independent review and approval.

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The inspectors reviewed NCS staff qualification records and conducted interviews to verify NCS engineers had the necessary education and experience and were qualified in accordance with license requirements.

Criticality Incident Response and Corrective Action The inspectors walked down various aspects of the criticality accident alarm system (CAAS) and interviewed licensee staff to determine whether the CAAS features met the applicable regulatory requirements in 10 CFR 70.24, and license commitments in the Section 5.3.2.5, Criticality Accident Alarm System, of the license application.

These aspects included whether components were resistant to environmental conditions and natural phenomena, whether detector failure was self-announcing, and whether the system had a uniform alarm signal and model of detection. The inspectors also walked down external portions of the CAAS and portions of the barriers and postings used to divide areas where there is a negligible risk of criticality (in accordance with Section 1.3.11.3 of the license application) from those where hazardous amounts of fissile material may be present.

The inspectors also interviewed management and walked down the CAAS panel in the licensees emergency command center to determine whether the licensee maintained NCS-related emergency response capability consistent with emergency plans and procedures. The inspectors conducted interviews to verify qualified NCS staff were readily available to advise the licensee in an emergency. The inspectors walked down accountability points and interviewed licensee staff concerning NCS support of emergency preparedness to determine whether personnel where trained to evacuate to accountability points in the event of a CAAS alarm, whether accountability points were located and monitored to minimize the potential for exposing evacuating personnel to radiation, and whether evacuation drills were conducted consistent with license commitments.

b. Conclusion

No violations of more than minor significance were identified.

2. Operational Safety (Inspection Procedure 88020)

a. Inspection Scope The inspectors reviewed portions of fuel manufacturing operations (FMO) to verify the licensee operated the facility safely and in accordance with 10 CFR 70 and the license application, as incorporated by reference in Safety Condition S-1 of Materials License SNM-1097. The inspectors selected two processes for review: (1) dry conversion process (DCP) vaporization (Node Group 201) and (2) fabrication area UO2 Grinders (Node Group 406). The inspectors review focused on verifying that the licensee implemented a safety program and applied appropriate management measures to IROFS in accordance with the licensing basis of the facility.

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Specifically, the inspectors reviewed operating procedures for UF6 handling operations in the DCP vaporization process (Node Group 201) to verify that IROFS 201-01, 201-05, and 201-07 were incorporated into the procedures as described in the Integrated Safety Analysis (ISA) Summary and the license application. The inspectors evaluated the procedures with respect to operating limits and operator responses for upset conditions to verify whether safety limits were adequately described in the procedures.

Additionally, the inspectors reviewed a sample of functional testing records for IROFS 201-01, 201-05, and 201-07 to verify that testing ensured that these safety controls were available and reliable to perform their function to comply with the performance requirements of 10 CFR 70.61. The inspectors also performed a walk down of DCP Vaporization Line 1 to verify the configuration of IROFS equipment was consistent with the description in the ISA documents and procedures. Additionally, the inspectors observed ongoing operations of DCP Vaporization Line 2, interviewed DCP control room operators, and reviewed a sample of operating data to verify that DCP vaporization autoclaves were operated consistent with procedures and within the bounds of the safety analysis.

For the fabrication area UO2 Grinders, the inspectors reviewed a sample of operating procedures to verify that IROFS 406-01, 406-05, 406-09, 406-10, 406-11, and 406-13 were incorporated into the procedures as described in the ISA Summary and the license application. Additionally, the inspectors reviewed records for IROFS 406-01, 406-09, 406-10, 406-11, 505-09, 505-10 and 505-14 to verify that the licensee performed testing, surveillance, or monitoring activities to ensure that these safety controls were available and reliable to perform their function to comply with the performance requirements of 10 CFR 70.61. The inspectors also performed a walk down of the UO2 Grinders process to verify the configuration of IROFS equipment was consistent with the description in the ISA documents and procedures. The walk down included parts of the Gad Grinders process area to verify whether IROFS 505-09, 505-10, and 505-14 were in place. Additionally, the inspectors observed ongoing operations of the UO2 Grinders process to verify that operations were consistent with procedures and within the bounds of the safety analysis.

The inspectors reviewed recent changes to operating procedures assigned to DCP vaporization and the UO2 Grinders (i.e. Change Requests 26229, 27761, 26842, and 29106) to verify the procedure changes were evaluated in accordance with 10 CFR 70.72 and Chapter 11 of the license application, Management Measures. The inspectors reviewed organization charts and interviewed licensee personnel to identify changes to the operations organization since the last NRC inspection in this area and verify that organizational changes, if any, were in accordance to the position-specific requirements of the license.

The inspectors reviewed training records regarding initial and continuing training programs to verify compliance with the training requirements in Chapter 11 the license application. The inspectors reviewed a sample of operator qualification records for IROFS to verify that the individuals were currently qualified on the systems and equipment to which they were assigned to operate and maintain.

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The inspector reviewed CAP procedures to verify that the licensee had a process in place to maintain records of IROFS failures in accordance with 10 CFR Part 70.62(a)(3). The inspectors reviewed a sample of CAP entries from the past 12 months (i.e. condition reports or CRs) to verify that safety-significant plant issues were entered in the program for resolution and corrective actions were initiated consistent with the CAP description in Chapter 11 of the license application. The review of CAP entries included the implementation of corrective actions and compensatory measures for IROFS-related issues documented in CRs. Additionally, the inspectors reviewed a sample of audits and self-assessments in the operations area to verify whether the licensee completed the assessments at the required frequency and entered significant audit findings into the CAP for resolution in accordance with Section 11.6, Audits and Assessments, of the license application.

b. Conclusion

No violations of more than minor significance were identified.

3. Fire Protection Annual (Inspection Procedure 88055)

a. Inspection Scope The inspectors reviewed licensee procedures and records, interviewed licensee staff, and toured plant areas containing safety controls and fire protection related IROFS to verify that fire protection equipment, systems, and features were implemented in accordance with Chapter 7 of the license application, Fire Safety, 10 CFR 70.61, 10 CFR 70.62, and WI-21-110-09, Fire Protection Program.

The inspectors walked down various plant areas, interviewed licensee personnel, and observed a combustible control audit to verify that combustible control IROFS were being implemented in accordance with CP-27-108, Combustible Control Program, and Section 11.6.4 of the license application, Fire Safety. The inspectors also walked down plant areas to verify whether flammable materials and flammable liquids were stored in marked cabinets and proper storage areas as specified in CP-27-108.

The inspectors interviewed licensee maintenance personnel and conducted walkdowns to verify that the physical condition of the fire detection devices did not show any physical damage, blockage, or potential interference with functionality. The inspectors also reviewed annual smoke detector, duct detector, and heat detector test records to verify that the fire detection devices remained functional to perform their intended safety functions and were tested in accordance with CP-27-100, Wilmington Site Fire Supervisory System Inspection, Test, and Maintenance Program. In addition, the inspectors interviewed security personnel and observed the fire alarm panel in the security base to verify that the security personnel would receive a visual and audible indication when a fire detection or protection system had been activated and to verify that the fire panel received power from two different sources.

The inspectors walked down sprinkler systems in FMO and the fuel manufacturing operations expansion (FMOX) building, reviewed sprinkler system testing and maintenance records and interviewed licensee personnel to verify that the fire protection systems were available, operable, and in proper material condition (e.g.,

sprinkler heads and nozzles were not missing, were not the wrong type, and were not obstructed, painted, or corroded).

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In addition, the inspectors performed the above review to verify where the fire protection systems had been properly tested to verify their ability to perform their safety function in accordance with the National Fire Protection Association (NFPA) 25 standard, and WI-27-110-09. The inspectors observed a monthly sprinkler system water supply valve inspection to verify that the water supply control valves to the system were open to ensure the fire water supply and pumping capability were operable and capable of supplying the water supply demand of the system.

The inspectors walked down fire hydrants, observed a monthly fire extinguisher inspection, observed a weekly fire engine inspection, and reviewed inspection records to verify that the firefighting equipment was provided at the designated locations, in proper material condition, and access was unobstructed, as required by the WI 110-09.

The inspectors walked down plant areas within FMO/FMOX and reviewed maintenance records to determine whether fire dampers, doors, and penetration seals were being maintained in a condition that would ensure they were available and reliable to perform their safety function in accordance with WI-21-110-09.

The inspectors reviewed licensee training records and procedures, observed an emergency response vehicle operation training, and interviewed staff to verify that the training of emergency response team members responsible for performing fire protection activities was performed as required by emergency organization training procedures.

b. Conclusion

No violations of more than minor significance were identified.

B. Radiological Controls

1. Radiation Protection (Inspection Procedure 88030)

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 10 CFR Part 20, the license application, and applicable procedures.

The inspectors reviewed employee training records and interviewed staff to verify that RP staff received training as specified in section 11.4 of the license application, Training and Qualifications, and as applicable to 10 CFR 19.12. The inspectors reviewed the RP Continuing Training Backbone Schedule to verify that the RP personnel were receiving the planned quarterly training.

The inspectors reviewed select radiation work permits (RWPs) to verify whether the licensee complied with section 4.2 of the license application, Radiation Safety Procedures and Radiation Work Permits, and WI-27-105-13, Radiation Work Permits at FMO. The inspectors observed work being performed under the general RWP, RWP 6000, to verify that the work being performed fell within the scope of the general RWP requirements and that workers were taking appropriate radiation protection measures.

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The inspectors observed calibration stickers and response checks on alpha, beta, and gamma detectors to verify that the licensee had a system to identify instruments and equipment due for periodic calibration or functional testing in accordance with 10 CFR 20.1501(c). The inspectors also observed technicians performing these checks to verify that the licensee appropriately responded to out-of-calibration equipment and tracked individual instruments. The inspectors reviewed documentation for NIST-traceable sources used for response checks, calibrations, and counting to verify compliance with section 4.11.1 of the license application, Calibration.

The inspectors observed surveying and smearing of incoming and outgoing shipments to verify that the work was performed in accordance with WI-27-105-08, Contamination Measurement and Control.

The inspectors reviewed documentation regarding leak testing of plutonium sources to verify compliance with section 4.5.4 of the license application, Leak Testing of Plutonium Alpha Sources. The inspectors observed postings to verify that the storage of sealed sources was in accordance with 10 CFR 20.1903(c). The inspectors also followed up on CR 33753 to verify whether the sealed source safe lock had been repaired.

The inspectors toured work and storage zones in radiologically controlled areas to verify that the licensee posted these zones in accordance with 10 CFR 20.1902 and that radiological signs and postings accurately reflected the radiological conditions within the posted areas. The inspectors observed signage for radioactive material containers in these areas to verify compliance with section 1.3.12 of the license application, Exemption to Posting Requirements.

The inspectors reviewed bulletin boards at the main employee entrance to verify whether the licensee was posting Notices in accordance with 10 CFR 19.11, including NRC Form 3, Notice to Employees.

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 handling of radioactive waste as part of an onsite inspection to evaluate whether the licensee had established, maintained, and implemented its waste management program in accordance with license requirements 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 tracking.

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The inspectors performed walk downs of selected radioactive material storage areas to verify that the storage areas had required postings, the proper material was being stored in the areas, the containers were properly labeled with their contents, and that the material was safely stored in accordance with procedural requirements: OP-1080.12.100, Outside Pad Storage General Information, OP-1080.20.100 Decon facility - General Information, and OP-1081.01.100, IncineratorGeneral Information.

The inspectors reviewed records pertaining to the classification and storage of low level radioactive waste and interviewed staff to verify that waste was being classified and stored in accordance with 10 CFR 61 and 10 CFR 20 Appendix G. Inspectors specifically reviewed LS-1801-01-01, Incinerator Log, LS-1080.20.02, HEPA/Prefilter log, and Storage Pad Audit Logs for January 17, September 16, and October 22, 2020. Inspectors also reviewed radiation survey reports of the storage pad.

Inspectors observed waste packages being incinerated to verify that the incinerator was being operated in accordance with OP-1081.01.201, Incinerator Startup, and OP-1081.-1.202, Incinerator Normal Operations. The inspectors interviewed staff to verify whether they were knowledgeable of the safety controls contained in OP-1081.01.300, Incinerator Process Operations.

The inspectors reviewed the installation and calibration of a new waste box monitor per Change Request 28713 - Replace Decon Box Monitors and WO 3736739 Annual Calibration and Verification of Fill Box Monitor to verify that it would perform its intended safety function of determining the uranic content of waste materials.

b. Conclusion

No violations of more than minor significance were identified.

3. Effluent Control and 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 the license application and associated regulations.

The inspectors performed walk downs of airborne stack monitoring stations, observed samples being taken, and observed a stack filter changeout to verify that the samples were being collected in accordance with EPI-O-6.0, Stack Sampling Program. The inspectors also reviewed CR 33172, Incinerator Stack Moisture Intrusion, to verify that airborne effluent monitoring equipment was being maintained in accordance with Chapter 9 of the license application, Environmental Protection.

The inspectors observed staff collecting and measuring samples of the process lagoon and then reviewed the Internal Chain of Custody records for the Final Process Lagoon Effluent to verify that the samples were collected in accordance with EPI-O-2.0, Environmental Sampling of the Final Process Lagoon System, Aeration Basin, and Site Dam.

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Inspectors observed soil samples being taken to verify that they were collected in accordance with EPI-O-7, Soil, Ditch, Vegetation, and State Split Sampling Program.

Inspectors reviewed Change Request 28387, Replace Rad1 Pipe Detectors and Calibrate, to verify that effluent monitoring equipment was being maintained and calibrated in accordance with the license application.

b. Conclusion

No violations of more than minor significance were identified.

C. Facility Support

1. Maintenance and Surveillance of Safety Controls (Inspection Procedure 88025)

a. Inspection Scope NRC inspectors performed a review of the maintenance and surveillance program to evaluate whether IROFS and other safety controls were available and reliable to perform their safety function; corrective actions were taken when IROFS or other safety controls failed or were degraded; and the licensee complied with the performance requirements of 10 CFR 70.61 and in Chapter 11, Management Measures, of the license application.

The inspectors reviewed functional test instructions (FTIs) for IROFS 201-01, 201-07, 406-04, 406-05, and 406-13 and various work orders (WOs) to verify compliance with Chapter 11 of the license application (see the attachment). The inspectors noted that FTIs and WOs were implemented via an established schedule but were allowed to be granted a one-time extension not to exceed 60 days. Based on interviews and observations, the inspectors noted that the licensee has a computerized system for locking out the functionality of processes if the required maintenance for IROFS (or other safety-related equipment) was not completed within the approved frequency.

The inspectors walked down the DCP Vaporization area and observed IROFS 201-01 and 201-07 to verify that they were in adequate material condition and were not impaired by other equipment from performing their intended safety function. The inspectors also walked down the UO2 Grinders area and observed IROFS 406-04, 406-05, and 406-13. The inspectors observed the licensee demonstrate the safety function on IROFS 406-04 and 406-13 on a process line that was not in service.

The inspectors observed maintenance activities performed on a redundant HF monitor and pipe detectors for UF6 to verify that the activities were conducted in accordance with the appropriate FTI. The inspectors observed communications among the control room operator, floor operator, and instrument technician to verify whether they constructively impacted the implementation of an on-going maintenance activity.

The inspectors reviewed FTI and WO records to verify whether they were reviewed and approved by supervision prior to returning repaired/recalibrated equipment to service. The inspectors walked down equipment used to perform maintenance functions to verify whether they were calibrated to NIST-traceable standards in accordance with procedures.

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The inspectors also walked down a spare parts/inventory facility to determine whether the licensee had a means of readily procuring replacement parts/equipment in accordance with procedures.

The inspectors reviewed training records of instrument technicians to verify compliance with section 11.4, Training and Qualifications, of the license application.

The inspectors interviewed the supervisor for the instrument technicians to determine whether the qualification requirements for these personnel were in accordance with the license application. The inspectors reviewed any personnel changes in the maintenance and surveillance program organization to verify compliance with position qualification requirements established by Chapter 2 of the license application, Organization and Administration.

The inspectors reviewed corrective actions (see the attachment) to verify that the licensee was in compliance with Chapter 11 of the license application. The inspectors also interviewed licensee personnel to determine whether corrective actions were assigned the appropriate severity level and were effective to correct and prevent recurrence of the issue in accordance with corrective action procedures.

The inspectors observed the daily production meeting to verify that the licensee addressed maintenance activities for that day and communicated the impacts of the activities on plant safety operations.

b. Conclusion

No violations of more than minor significance were identified.

2. Emergency Preparedness (IP 88050)

a. Inspection Scope The inspectors reviewed select aspects of GNF-As emergency preparedness (EP) program to verify compliance with Chapter 8 of the license application, the Radiological Contingency and Emergency Plan (RC&EP) Rev 27, and 10 CFR 70.

The inspectors interviewed staff and reviewed records to verify that the licensee established management controls to ensure the RC&EP and implementing procedures were maintained up to date and to verify that any changes to the EP program did not decrease the overall effectiveness. The inspectors reviewed a sample of the emergency response organization (ERO) implementing procedures, observed a quarterly procedure check, and interviewed staff to verify whether current copies of the EP procedures were readily available to members of the emergency response organization, and were maintained current in the appropriate field locations. The inspectors interviewed licensee staff, local fire fighter staff, and reviewed the licensees pre-fire plans to determine whether NCS precautions for firefighting were included in the emergency procedures. The inspectors also reviewed the licensees pre-fire plans to determine whether they were current and available at required field locations.

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The inspectors reviewed training records, interviewed licensee staff regarding emergency organization training, and reviewed ERO drills since the last inspection.

The inspectors conducted the interviews and reviews to verify that the licensee provided training for personnel that use emergency equipment in the field and to verify that ERO members received training and participated in drills at least annually to remain qualified as required by the RC&EP. The inspectors interviewed offsite personnel to verify that the licensee provided training for offsite personnel including special instructions, orientation tours, and refresher training, as required by the RC&EP.

The inspectors reviewed the written agreements with offsite support agencies to verify that Memorandums of Understanding between the off-site organizations and the licensee were maintained current as required by the RC&EP. The inspectors reviewed records and interviewed the New Hanover County Fire Captain and the New Hanover County Senior Emergency Management Specialist to verify that the licensee and offsite support agencies maintained an understanding of the written agreements, and that the licensee invited the offsite organizations for training and drill participation, as required by the RC&EP.

The inspectors reviewed the 2020 3rd and 4th Quarter Drills to verify that the licensees program ensured that emergency exercise objectives and scenario details were kept confidential from participants. The inspectors reviewed the drill package to verify that the licensees emergency drill had a credible, technically correct, and challenging scenario that tested key elements of the emergency plan, procedures, equipment, and the onsite and offsite response organizations. The inspectors reviewed drill schedules to verify that drills and exercises were conducted within the timeframes required by the RC&EP. The inspectors reviewed records and interviewed staff to verify that a critique of the response occurred and that the items identified were being captured and addressed in the corrective action program.

The inspectors observed the emergency equipment in the main emergency control center (ECC) and observed the Quarterly ECC Surveillance, CP-28-113-F10, to verify whether the equipment was maintained in a ready state as required by the RC&EP.

The inspectors also observed the storage of emergency equipment in the alternate ECC and the offsite ECC, New Hanover Country Emergency Operations Center, to verify that the equipment was maintained in a ready state, as required by the RC&EP.

The inspectors reviewed the accountability procedure and observed onsite rendezvous areas to verify that pre-determined accountability muster locations were accessible and contained operable communications and other equipment, as specified in the RC&EP.

The inspectors reviewed documentation of events that occurred since the last EP inspection, which required the implementation of the Emergency Plan, to verify that problems or deficiencies associated with the Emergency Plan or implementing procedures were documented, investigated, and corrected as required.

b. Conclusion

No violations of more than minor significance were identified.

3. Plant Modifications - Triennial (Inspection Procedure 88072) 13

a. Inspection Scope The inspectors reviewed the licensees configuration management program to determine whether the licensee established a process to evaluate, implement, and track cumulative modifications to the facility in accordance with 10 CFR 70.72 and license application Chapter 11, Management Measures. The inspectors reviewed configuration management procedures and interviewed licensee senior managers, supervisors, and engineers to verify whether the configuration management program was being implemented in accordance with the applicable requirements.

The inspectors reviewed a selection of plant modification packages (i.e. Facility Change Requests (FCRs)) to determine whether the licensee was implementing their configuration management program as described in the license application, program procedures, and as required by 10 CFR 70.72 and 10 CFR 70.62(d). Specifically, the inspectors holistically reviewed FCRs associated with Node 202, Dry Conversion Process Conversion, in DCP to verify that an adequate technical basis was established, and the design assumptions were accurate for the modifications as required by 10 CFR 70.72. The inspectors reviewed the FCRs to ensure modifications to the Node 202 Conversion process, and their respective interfaces with other systems did not adversely impact the safety basis of the ISA or safety programs as required by 10 CFR 70.72(a)(6), or invalidate the natural phenomena hazards (NPH) structural analysis as required by 10 CFR 70.62(c). The inspectors also verified that 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. The FCRs reviewed were as follows:

• CR-21195, Line 1 Vaporization/Conversion/Powder Operations - Installed new Digital Control System (DCS) and associated hard-wired IROFS, initiated 2/18/2016, The new DCS included a new General Electric Mark VIe DCS to replace the existing Provox DCS for Line 1. Reassigned 7/28/2020. Lines 2 and 3 were converted later.

• CR-27934, Update Instrument Setpoints to Provide IROFS Trip Offset. The flexibility of the offset, somewhat above IROFS setpoint requirements, allowed for calibration device tolerance. Conversion line 1. Initiated 7/8/2019.

Completed 11/20/2019.

• CR-26338, Remove DCP Recycle from ISA. This included the removal of IROFS 202-08, 202-09, 202-34. The associated recycle hardware had been completely removed. Applicable to lines 1, 2, and 3. Initiated 5/9/2019.

Completed 10/8/2018.

• CR-13298, Update Safety Basis to reflect new DCP hydrogen gas detection and alarm system, completed 11/19/2015. Included ISA docs QRA-202/PHA-202. Relocated hydrogen gas main supply pipelines from within the process area to the rooftop as much as possible.

• CR-11936, Modify hydrogen gas system for DCP Conversion Lines, completed 8/7/2014. Relocated hydrogen main supply pipelines from within the process area to the rooftop as much as possible.

The inspectors reviewed open work requests and temporary operating instructions for Node 202 and interviewed plant staff to determine if the selected modifications were operated outside of their normal configuration and whether there was any adverse impact to the systems safety basis.

14

The inspectors verified that selected plant modifications met the design criteria specified in applicable modification packages. The inspectors reviewed a sample of 10 CFR 70.72 evaluations for changes made to Node 202 to determine whether the licensee adequately evaluated the need for NRC pre-approval of select facility modifications. The inspectors reviewed applicable design basis documents to determine whether the licensing documents had been updated or were in the process of being updated promptly to reflect the modifications as required by 10 CFR 70.72(e).

The inspectors reviewed the licensees document retention practices and procedures to verify compliance with the record retention requirements in 10 CFR 70.72(f). The inspectors also reviewed the training records of licensee personnel conducting the 10 CFR 70.72 evaluations to verify that they were qualified to perform the evaluations in accordance with procedural requirements.

The inspectors reviewed the selected modifications to verify that the licensee properly classified minor and administrative modifications in accordance with License Application Chapter 11, Management Measures and to verify that the design basis, licensing basis and performance capabilities of IROFS had not been degraded through the modifications.

The inspectors performed walk downs and reviewed post-modification testing documentation related to the selected modifications to verify the system condition and tested capability were appropriate and consistent with the design basis and system functionality. The inspectors reviewed post-modification testing procedures and test results to verify that the acceptance criteria for system parameters were met and valid, no unintended system interactions occurred, and IROFS performed their intended safety functions, as required by 10 CFR 70.62(d). The inspectors compared the field condition with the modification packages to verify the following: the modifications were implemented in accordance with the approved design documents in the modification packages, the assumptions in the ISA were valid based on the actual configurations, and that operation of the modified processes and their management measures could be accomplished as assumed in the ISA to ensure the IROFS were available when needed.

The selected modifications included instrumentation and controls (I&C) changes associated with the Node 202 Conversion process to verify the licensee had adequately established set points to prevent exceeding criticality or chemical safety exposure limits. The inspectors reviewed records and calibration stickers to verify that the measuring and test equipment used in the surveillances was properly calibrated in accordance with licensee application requirements.

b. Conclusion

No violations of more than minor significance were identified.

D. Other Areas

1. Review of Confirmatory Order Section V Item 8 (Inspection Procedure 92703)

a. Inspection Scope The inspectors reviewed the licensees actions regarding Confirmatory Order (CO)

Section V, Item 8 (ML17348A144), which required GNF-A to have existing supervisors 15

engaged in licensed facility activities, as the date of issuance of the CO, complete initial Front Line Supervisor Nuclear Safety Leadership training, informed by INPO 04-003, Guidelines for Effective Nuclear Supervisor Performance. It also required GNF-A to have new front line supervisors engaged in licensed facility activities complete the training within six months of assuming supervisor responsibilities for a period of three years after issuance of the CO and to make the training materials available to the NRC for review.

The inspectors reviewed GNF-A front line supervisor training materials to verify that aspects of INPO 04-003 guidelines were evident and used as required by CO Item V.8. The inspectors also reviewed training records for existing and new front line supervisors throughout the period of December 14, 2017 until December 14, 2020 to verify that the completion of management training was consistent with CO Item V.8 (ADAMS ML17348A144).

b. Conclusion

The inspectors determined that GNF-A has met the requirements as stated in the CO,Section V, Item 8. This item is considered closed.

E. 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 October 8, 2020, December 3, 2020, and December 11, 2020 to Mr. Brad Beard, on October 22, 2020 to Mr. Scott Murray, and on October 29, 2020 to Mr. Jonathan Rohner.

Proprietary information was discussed but not included in the report.

16

SUPPLEMENTAL INFORMATION

1. KEY POINTS OF CONTACT Licensee personnel Name Title M. Baker Engineer, Ceramics Area J. Banfield Nuclear Safety Engineer B. Beard Plant Leader P. Boscaljohn FMO Training Specialist S. Brown Configuration Management Controller G. Bryan Fire Technician C. Davidson Lead Fixed Facilities Specialist J. DeGolyer Manager, Nuclear Safety Analysis D. Ebali Senior NCS Engineer F. Edens Instrument Technician W. Greer Process Engineer R. Hart Fire Technician B. Henderson Radiation Protection Manager A. Humphreys Manufacturing Programs Leader J. Kinlaw Maintenance Technician C. Kotei Radiation Safety Manager T. Kuhr Lead Fixed Facilities Specialist K. McDonald Fire Captain S. Murray Manager, Facility Licensing P. Nobles Instrument Technician P. Ollis Facility Licensing L. Paulson Program Manager, Criticality Safety D. Raines Fire Safety & Emergency Response Coordinator A. Reedside Environmental Specialist J. Rohner Manager, Fuels Environmental, Health, and Safety P. Rose Facility Licensing D. Russ Instrument Technician C. Savage DCP Area Engineer C. Smith Instrument Technician B. Stone Program Manager, ISA R. Thigpen Maintenance Coordinator/Instrument Technician J. Thomas Nuclear Safety Engineer M. Venters Manager, Senior Fixed Facilities Staff G. Waites Maintenance Supervisor, Instrumentation Team Leader K. Williams Environmental Specialist

2. LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Closed CO Section V CO GNF-A shall have existing supervisors engaged in licensed facility Item 8 activities, as of the date of issuance of the CO, complete initial Front-Line Supervisor Nuclear Safety Leadership training, which will be informed by INPO 04-003, Guidelines for Effective Nuclear Supervisor Performance. For a period of three years after issuance of the CO, new GNF-A frontline supervisors engaged in licensed Attachment

facility activities shall complete this training within six months of assuming supervisory responsibilities. GNF-A shall make the training materials available to the NRC for review. (Section D.1)

3. INSPECTION PROCEDURES USED 88015 Nuclear Criticality Safety 88020 Operational Safety 88025 Maintenance and Surveillance of Safety Controls 88030 Radiation Protection (Appendix A) 88035 Radioactive Waste Processing, Handling, Storage, and Transportation 88045 Effluent Control and Environmental Protection 88050 Emergency Preparedness 88055 Fire Protection (Annual) 88072 Plant Modifications (Triennial) 92703 Follow up of Confirmatory Action Letters or Orders

4. DOCUMENTS REVIEWED Records:

1Q 2020 RP Continuing Training, Regulatory Controls Overview, dated 8/11/2020 2Q 2020 RP Continuing Training, Contamination Control and Monitoring, dated 6/26/2020 3Q2020 Nuclear Safety Audit - UO2 Grind, Gad Grind, UO2 Rod Load, Gad Rod Load, Final Weld, UO2 Pellet Storage, Gad Pellet Storage, Cut-off Lathe, Off-line Sort, Rod Storage, dated 9/25/2020 3Q2020 Nuclear Safety Audit - Engineering, Chemet and Environmental Labs, dated 9/28/2020 4Q 2019 RP Monitor Training, 49CFR 172.704(A) dated July 29, 2020 Calibration Work Order # 905463, IROFS, Annual Calibration Verification of Current Trip, Equipment F8S12100, Reactor High Pressure Interlock, Tag # PTSH12100. For Moore Industries High Level current Trip (HLPGR), for two wire transmitters.

Calibration Work Order # 2157777, IROFS, Annual Calibration Pressure, PT12100 Kiln Reactor Pressure, completed 6 SEP 2020, this was a retest record of same test 905463 completed 7/2/2019.

CP-28-113-F01, Quarterly Procedure Surveillance (ECC), dated 12/02/2020 CP-28-113-F03, Quarterly Procedure Surveillance (Off-Site), dated 9/02/2020 CP-28-113-F16, Quarterly IT Software Surveillance, dated 12/02/2020 CSA-201.00.100, Criticality Safety Analysis, DCP Vaporization Process, Revision 2, Approved per CR 29239, dated September 2020.

CSA-202.00.100, Criticality Safety Analysis, DCP Conversion Reactor Kiln, Revision 2, Approved per CR 25303, dated September 2017.

CSA-204.00.100, Criticality Safety Analysis, DCP Powder Outlet, Revision 2, Approved per CR 28558, dated May 2020 CSA 505.071015, Gad Ministacker at 5% Enrichment, Rev. 3 CSA 505.080422, Grinder Apitron Filter Housing, Rev. 0 CSA 507.00.100, Gad Dry Scrap Recycle, Rev. 1 CSA 900.00.100, Homogenous Uranium Subcritical Limits, Rev. 3 CSA 900.02.100, Heterogenous Uranium Subcritical Limits, Rev. 0 CSA 900.03.100, Criticality Safety Analysis Sintered Pellets, Rev. 1 CSA 1040.11, Line 5 Grinders, Rev. 1 2

Daily Counter Efficiency Log, dated October 08, 2020 EHS Compliance Auditor Certification, (Various), dated March 2, 2020 Emergency Organization Training Verification Report, dated 10/15/20 EP-010 Emergency Operations Training - Annual Requalification 2020 Records EP-011 Minimum EO Staff Training - Annual Requalification 2020 Records FTI Test Number 201-00, Revision 0.1, completed on 01/04/2020, 09/29/2020, & 10/1/2020 FTI Test Number 201-01A, Revision 0, completed on 09/29/2020 and 10/01/2020 FTI Test Number 201-01B, Revision 0, completed on 09/29/2020 and10/01/2020 FTI Test Number 201-05A, Revision 0, completed on 01/05/2020 FTI 201-05A Line 3, Autoclave Leak Detection System AT#1309, completed on 10/1/2020 FTI 201-05B Line 2, Autoclave Leak Detection System AT#1329, completed on 1/5/2020 FTI 201-05B Line 3, Autoclave Leak Detection System AT#1329, completed on 10/1/2020 FTI Test Number 201-07, Revision 0, completed on 8/26/19, 01/04/2020, and 10/02/2020 FTI 201-07 Line 1, Vaporization Room HF Alarm and Automatic Shutdown, AT#1310, AT#1330, AT#1350, complete on 8/26/2019 FTI 201-07 Line 2, Vaporization Room HF Alarm and Automatic Shutdown, AT#1310, AT#1330, AT#1350, completed on 1/4/2020 FTI 201-07 Line 3, Vaporization Room HF Alarm and Automatic Shutdown, AT#1310, AT#1330, AT#1350, completed on 11/2/2020 FTI 202-00, Functional Test Instruction (FTI), Test 202-00, Common IROFS Devices Conversion, Revision 0, Approved CR#: 22092 FTI 202-18, Functional Test Instruction (FTI), Test 202-18, Kiln Zone A Temperature, TE#2049/2051, Reference ORA-202/IRS 202-18, Approved per CR# 22105, Revision 0 FTI 202-22, Functional Test Instruction (FTI), Outlet Hot Box Temperature, TE#2011A, Reference QRA-202, IRS 202-22, IROFS to Isolate hydrolysis and pyro-hydrolysis steam supply valves on temperature that is below set point.

FTI 202-33, Functional Test Instruction (FTI), Test 202-33, Hallway H2 detector IROFS, DCP, Revision 0.1, Approved CR#: 27035 FTI-202-33, Conversion Hallway Alarm with Hydrogen Isolation Line 1, completed on 3/30/2020 FTI-202-33, Conversion Hallway Alarm with Hydrogen Isolation Line 2, completed on 3/30/2020 FTI-202-33, Conversion Hallway Alarm with Hydrogen Isolation Line 3, completed on 3/30/2020 FTI Test Number 203-00B, Revision 1.4, completed on 10/28/2020 FTI-204-01A, Kiln Hatch N2 Purge Pressure Alarm PT#2115, completed on 1/4/2020 FTI Test Number 406-04 F2, Revision 0, completed on 07/14/2020 & 10/16/2020 FTI Test Number 406-13 F2, Revision 0, completed on 07/14/2020 & 10/16/2020 FTI 1040.12, Functional Test Instruction Test F2, completed on 10/26/2020 FTI Test Number F3, Revision 2.3, completed on 10/21/2020 GNFA Internal Chain of Custody Final Process Lagoon Effluent, dated 10/7/2020 GNFA Radiation Survey Report Pad 5 and 6B, dated 4/4/2019 GNFA Radiation Survey Report, Special Survey of Wooden Trash Boxes, dated 10/22/2020 GNFA Radiation Survey Report, Special Survey, dated 10/23/2020 IRS 200-00, IROFS Requirements Specification (IRS), Common Recourses, Pyro-Hydrolysis Steam, Hydrolysis Steam, Conversion UF6 Block Valve, Vaporization UF6 Double Block Valves, Vaporization First Block Valve, Cooling Hopper Discharge Valves, Approved CR#: 22146, Revision3 IRS 200-33, IROFS Requirements Specification (IRS), Conversion Hallway Hydrogen Alarm, Approved CR#: 20858, Revision 3 IRS 202-02, IROFS Requirements Specification (IRS), Reactor High Pressure Interlock, Revision 1 3

IRS 202-18, IROFS Requirements Specification (IRS), Kiln Zone A Temperature, Revision 2 IRS 202-26, IROFS Requirements Specification (IRS), East Hydrogen Alarm with Hydrogen Valve Isolation, Revision 0 IRS 204-01, IROFS Requirements Specification (IRS), Kiln Hatch Hydrogen Pressure Alarm, Approved CR#: 22146, Revision 1 IRS-204-02, IROFS 204-02 Cooling Hopper Moisture Detection System, Rev. 02 LS-1080.20.02 Hepa/Prefilter log, dated 9/26/2020 LS-1801-01-01 Incinerator Log, dated 10/7/2020 LS 2310.00.106, Detector Functionality Test Log, completed 1/30/2020 Monthly Storage Pad Audit Log for 10/22/2020 New DCP Employee Orientation - Criticality Safety, dated March 2020 New Employee Orientation - Criticality Safety, dated September 2019 New Hanover County Emergency Management MOU, dated 7/2/2019 New Hanover County Fire Rescue MOU, dated 5/3/2019 New Hanover Regional Medical Center and New Hanover Regional Emergency Medical Services, dated 7/3/2019 NOS-2019-30, GNF-A 2019 NCS Independent Triennial Audit Focused Self-Assessment Report NS-2020-06, GNFA Criticality Safety Engineer Qualification, dated May 4, 2020 NS-2020-07, GNFA Criticality Safety Engineer Qualification, dated June 4, 2020 PHA-101, Process Hazard Analysis, ISA Reference Report for the DCP Conversion Node Group, Approval CR#: 13298, Revision 4 PHA-202, ISA Reference Report for the DCP Conversion Node Group, Rev. 12 Portable Instrument Checkout Log, dated October 08, 2020 Radioactive Sealed Source Leak Test Record dated 09/22/2020, 05/04/2020, 03/25/2020, 01/16/2020 QRA-202, DCP - Conversion, Rev. 08 QRA-202, DCP - Conversion, Rev. 09 QRA-201, DCP Vaporization, Rev. 16 QRA-202, DCP - Conversion, Rev. 22 QRA-406/505, Fabrication-Grind, Node 406-505 IROFS, Revision 16 (IROFS 406-04, 406-05, & 406-13)

Radiation Worker Safety Criticality Safety, October 2019 Radiation Worker Training: Criticality Safety Level 2 Exam (A)

Radiation Worker Training: Criticality Safety Level 2 Exam (B)

RP Continuing Training Backbone Schedule 2018 to 2021 RWP 6000 Rev. 0, dated 01/01/2020 RWP Listing Report from 01/01/2020 to 10/06/20 TD 406-05, Apitron Filter System, Rev. 0 TD 406-13, Grinder Process Scale Interlock, Rev. 1 Tennelec Count Rate, Alpha Efficiency, Beta Efficiency, and Background, dated 10/5/2020 Training records for several instrument technicians Weekly Storage Pad Audit Log for 1/17/2020 Weekly Storage Pad Audit Log for 9/16/2020 Wilmington Nuclear Energy Audit Report, dated 11/11/2019 WO 1062542, Annual Duct Detector PM WO 1062544, Annual Smoke Detector PM WO 1062546, Annual Heat Detector PM WO 3120850, Annual Calibration: Calibration ASHCROFT ATE-100 Calibrator, dated 10/21/2020 4

WO 3120852, Annual Calibration: Calibration of FLUKE 743 Calibrator, dated 9/08/2020 WO 3623747, Monthly Calibration: DCP Conversion HF Analyzer, dated 9/28/2020 WO 3736739 Annual Calibration and Verification of Fill Box Monitor Procedures:

CP-06-100, Document Control Process, Rev. 23.4 CP-06-216, Functional Test Instructions, Revision 2.0, dated 5/5/2020 CP-12-102, Calibration Program for Instrumentation and Controls, Revision 2.2, dated 6/29/2020 CP-16-108, Corrective Action Program, Revision 13.0, dated 9/16/2020 CP-17-101, Product Quality Assurance Records, Rev. 8.4 CP-17-103, Nuclear Safety Records, Revision 1.0, dated 9/4/2015 CP-18-104, EHS Regulatory Compliance Audits, Rev. 3.1, dated 6/24/2020 CP-20-100, Conduct of Training, Rev. 6.0 CP-20-103, Nuclear Safety Training, Rev. 2.1 CP-24-100, Wilmington Maintenance Administration, Rev. 3.0 CP-24-100-F02, Pre-Job Brief Checklist, Revision 0, 10/01/2014 CP-27-104, Nuclear Safety Assurance, Rev. 2 CP-28-113-F04, Monthly RP Surveillance (ECC)

EPI-O-2.0, Environmental Sampling of the Final Process Lagoon System, Aeration Basin, and Site Dam, Rev. 47, dated 1/15/2020 EPI-O-6.0, Stack Sampling Program, Rev. 76, dated 6/6/2020 EPI-O-7, Soil, Ditch, Vegetation, and State Split Sampling Program, Rev. 47, dated 6/8/2020 FTI Test Number 201-01A, Revision 0, (blank copy)

FTI Test Number 201-07, Revision 0 (blank copy)

FTI-202-00, Common IROFS Devices, Rev. 0 FTI-202-33, Conversion Hallway Alarm with Hydrogen Isolation, Rev. 0.1 FTI Test Number F1, Revision 1.2 (blank copy)

FTI Test Number F2, Revision 1.3 (blank copy)

OP-201.00.100, DCP Vaporization-General Information, Rev. 3 OP-201.00.203, DCP Vaporization-Autoclave Loading, Rev 4 OP-201.00.204, DCP Vaporization-Vaporization Process, Rev. 2 OP-201.00.206, DCP Vaporization-Autoclave Unloading, Rev. 4 OP-201.00.209, DCP Vaporization-Abnormal Operations, Rev. 1 OP-201.00.210, DCP Vaporization-Alarm Response and Emergency Operations, Rev. 2 OP 1040.12.100, UO2 Pellet Grinder-General Information, Rev. 4 OP 1040.12.202, UO2 Pellet Grinder-Start Up, Rev. 2 OP 1040.12.203, UO2 Pellet Grinder-Normal Operations, Rev. 4 OP 1040.12.208, UO2 Pellet Grinder-Hood Inspection and Scrap Disposal, Rev. 1 OP 1081.01.100, IncineratorGeneral Information, Rev. 02, dated 5/29/2018 OP 1081.01.201, Incinerator Startup, Rev. 10, dated 1/8/2020 OP 1081.01.202, Incinerator Normal Operations, Rev. 14, dated 5/21/2020 OP 1081.01.203, Incinerator Shutdown, Rev. 04, dated 1/8/2020 OP 1081.01.300, Incinerator Process Operations, Rev. 05, dated 5/21/2020 OP 1080.12.100, Outside Pad Storage General Information, Rev. 03, dated 8/5/2019 OP 1080.12.201, Outside Pad Storage-Storage Requirements, Rev. 09, dated 5/18/2020 OP 1080.12.202, Outside Pad StorageAbnormal and Emergency Operations, Rev. 01, dated 3/29/2017 5

OP 1080.13.0, Monthly Storage Pad Audit Rev. 1, dated 5/20/2020 OP 1080.20.100 Decon facility - General Information, Rev. 05, dated 7/8/2020 OP 1080.20.300 Decon Facility Process Information Rev. 01, dated 10/17/2018 RWP 6000, Controlled Access Areas, Revision 0 RWP 6002, All Controlled Areas, Revision 0 Temporary Operating Procedure (TOP) 28823, Surgical Mask Use in FMO & Incinerator Contamination Areas, Revision 1 WI-06-100-22, CAA Operating Procedures, Rev. 0.5, dated 12/10/2019 WI-16-106-02, Configuration Management Program - Nuclear Manufacturing Operations, Rev. 15, dated 05/05/2020 WI-16-108-01-F03, Priority Screening Criteria Matrix, Revision 1, dated 07/30/2020 WI-18-104-22, Internal Nuclear Safety Audits, Rev. 4 WI-27-104-15, NCS Calculational Methods and Verification, Rev. 3, dated 3/6/2020 WI-27-105-08, Contamination Measurement and Control, Rev. 6.0, dated 10/17/2018 WI-27-105-13, Radiation Work Permits at FMO, Rev. 5.1, dated 01/09/2019 Change Requests Change Request 3364, Line 2 Conversion Outlet Hatch Valve Change, dated 8/11/2008 Change Request 8892, Change Line 3 Recycle Hatch Valves, dated 11/13/2012 Change Request 8893, Update Line 3 Conversion to Match Line 1 Conversion Recycle Capability, dated 8/24/2012 Change Request 11838, Remove HF Processing from the Scope of the ISA, dated 1/1/2014 Change Request 11936, Modify H2 System for DCP Conversion Lines, completed 8/7/2014 (Relocated H2 main supply pipelines from within the process area to the rooftop as much as possible.)

Change Request 13298, Update Safety Basis to reflect new DCP H2 system, completed 11/19/2015, Includes ISA docs QRA-202/PHA-202, (Relocated H2 main supply pipelines from within the process area to the rooftop as much as possible.)

Change Request 13305, Update FTI to Reflect Revision to Conversion Hydrogen System, dated 2/18/2015 Change Request 13314, Move H2 Sensor AE12320 Up to Ceiling Level of Conversion Room, dated 7/10/2014 Change Request 13315, Move H2 Sensor AE22320 Up to Ceiling Level of Conversion Room, dated 7/10/2014 Change Request 16973, Remove IROFS 202-30 from Use, dated 5/21/2015 Change Request 21195 Line 1 Vaporization/conv/PO - Install New DCS and Hardware IROFS, initiated 2/18/2016, Install new Mark VIe DCS to replace Provox for Line 1.

Reassigned 7/28/2020.

Change Request 25303, CSA 202.00.100 DCP Reactor Kiln (Rev. 2), dated 1/18/2018 Change Request 26229, Vaporization Cylinder Handling, dated 4/5/2018 Change Request 26338 Remove DCP Recycle from ISA, includes IROFS 202-08, 202-09, 202-34. Lines 1, 2, and 3. Initiated 5/9/2019. Completed 10/8/2018.

Change Request 26842, Vaporization Leak Indication and Manual Sample Update, dated 9/27/2018 Change Request 27294, QRA Revision to Chemical Accident Sequences, dated 1/11/2019 Change Request 27761, FFM Posting on Vaporization Prior to Startup on Maintenance Activities, dated 5/15/2019 Change Request 27934 Update Instrument Setpoints to Provide IROFS Trip Offset, allows offset above IROFS setpoint requirements to allow for calibration device tolerance.

Conversion line 1. Initiated 7/8/2019. Completed 11/20/2019.

6

Change Request 28387Replace Rad1 Pipe Detector and Calibrate, dated 11/21/2019 Change Request 28558, CAS 204.00.100 DCP Powder Outlet (Rev. 2), dated 6/5/2020 Change Request 28713 - Replace Decon Box Monitors Change Request 28888, Update Powder Outlet Handling of Moisture Analysis, dated 6/17/2020 Change Request 29106, 1020.12 & 1070.47 Shut Down Update, dated 6/19/202 Condition Reports Written as a Result of the Inspection:

CR 35735 Condition Reports Reviewed:

CR 26243 l CR 26252 l CR 26269 l CR 26270 l CR 26271 l CR 26110 l CR 33397 CR 33832 l CR 34210 l CR 34575 l CR 32255 l CR 33172 l CR 33753 l CR 35398 CR 30280 l CR 33417 l CR 33606 l CR 33933 l CR 34072 Other Documents:

2020 4th Quarter Evacuation Drill Scenario Package Amendment Request to Remove Hydrofluoric Recovery from the Integrated Safety Analysis (Technical Assignment Control No. L33826), dated 12/19/2013 BOM for HF Detectors Compliance Calendar IROFS 406-01/505-01 Process Equipment Barrier - Grinder, dated 4/22/2020 Compliance Calendar IROFS 406-09 Pellet Storage Cabinet - Safe Geometry, dated 10/6/2020 Compliance Calendar IROFS 406-10 Pellet Storage Cart Free Draining, dated 1/24/2020 Compliance Calendar IROFS 406-11 Pellet Storage Cart - Safe Geometry, dated 1/24/2020 Compliance Calendar IROFS 505-09 Process Equipment Barrier - Ministacker, dated 4/7/2020 Compliance Calendar IROFS 505-10 Ministacker - Safe Geometry, dated 4/7/2020 Compliance Calendar IROFS 505-14 Buffer Storage Cabinet - Safe Geometry, dated 1/24/2020 DCP Exhaust Unit Run Time, dated 10/7/2020 DCP Operator Training Records for M. Foster, D. Lewis, J. Lochbihler, B. Muncy DCP Vaporization, Node 201 IROFS, Revision 16A, (IROFS 201-01, 201-07)

Eaton Safety Relay, emergency stop/protective, P/N ESR5-NO-31-24 VAC/DC, Cat #

118702, Auto Reset, rated SIL3, Users Manual Emergency Organization Training Verification Report, dated 10/15/2020 I05.1356 32917A, Line 3 - Conversion, Rev. B, dated 8/17/2012 I05.1356 32917B, Line 3 - Conversion, Rev. C, dated 8/17/2012 IROFS Refresher Training 2020, Dry Conversion Process IROFS Refresher Training 2020, Fabrication Area - All IRS 201-01, IROFS 201-01 Vaporization Cylinder Temperature and Pressure Control, Revision 2, dated 11/16/2017 IRS 201-05, IROFS 201-05 Vaporization Autoclave Leak Detection System, Rev. 1 IRS 201-07, IROFS 201-07, Vaporization Room HF Alarm and Automatic Shutdown System, Revision 2, dated 12/14/2016 ISA Reviewer Change Evaluation Form for Change Request 27294, dated 1/18/2019 Listing of all FTIs in the Grinder Area Maintenance Organization Chart Moore Industries STA HLRPG Programmable Current/Voltage Safety Trip Alarm, Users Manual 225-748 01L (Feb 2017), Rated SIL3, www.hiinet.com 7

NOS-2019-30 2019 Triennial NCS Assessment BGS-COR-0060, dated November 2019 QRA-201, Presentation: Revision 15 of QRA-201: Vaporization Radiological Contingency and Emergency Plan, Rev. 28, dated 11/18/2019 RC&EP Drill Report - 2020 Q3 IED Qual Drill, dated 8/20/2020 RC&EP Drill Report - 2020 Q4 Drill Scenario, dated 10/8/2020 TD 201-01, Vaporization Cylinder Temperature and Pressure Control System, Rev. 0 TD 201-05, Autoclave Leak Detection System, Rev. 1 TD 201-07, Vaporization Room HF Alarm and Automatic Shutdown System, Rev. 1 TD 406-01, Process Equipment Barrier - Grinder TD 406-05, Apitron Filter System, Rev. 0 TD 406-09, Pellet Storage Cabinet - Safe Geometry, Rev. 0 TD 406-10, Pellet Storage Cart Free Drain, Rev. 0 TD 505-09, Process Equipment Barrier - Ministacker, Rev. 1 TD 505-10, Ministacker - Safe Geometry, Rev. 0 TD 505-14, Buffer Storage Cabinet - Safe Geometry, Rev. 0 TD 900-04, Spill Identification and Cleanup, Rev. 2 UO2 Grinder Operator Training Records for D. Boltz, J. Crosby, L. Hayes, and L. Smith Wilmington Audit Report SNM 1097 Areas, dated 11/11/2019

5. ACRONYMS AND INITIALISMS 10 CFR Title 10 of the Code of Federal Regulations ADAMS NRCs Document System CAAS Criticality Accident Alarm System CAP Corrective Action Program CSA Criticality Safety Analysis CR Change Request DCP Dry Conversion Process ECC Emergency Control Center EP Emergency Preparedness ERO Emergency Response Organization FMO Fuel Manufacturing Operations FTI Functional Test Instruction I&C Instrumentation & Controls IROFS Items Relied on for Safety ISA Integrated Safety Analysis NCS Nuclear Criticality Safety NFPA National Fire Protection Association NPH Natural Phenomena Hazards NRC Nuclear Regulatory Commission QRA Quantitative Risk Assessment REV. Revision RP Radiation Protection RWP Radiation Work Permit WO Work Order 8