ML21113A106

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BWXT Nuclear Operations Group Nuclear Regulatory Commission Integrated Inspection Report 70-27 2021-001
ML21113A106
Person / Time
Site: BWX Technologies
Issue date: 04/23/2021
From: Eric Michel
NRC/RGN-II/DFFI/FFB2
To: Bittner J
BWXT
References
IR 2021001
Download: ML21113A106 (17)


Text

April 23, 2021 Mr. James J. Bittner Vice President and General Manager Nuclear Operations Group, Inc.

BWXT Nuclear Operations Group, Inc.

P.O. Box 785 Lynchburg, VA 24505-0785

SUBJECT:

BWXT NUCLEAR OPERATIONS GROUP, INC. - INTEGRATED INSPECTION REPORT 07000027/2021001

Dear Mr. Bittner:

On March 31, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at BWXT Nuclear Operations Group, Inc. On April 22, 2021, the NRC inspectors discussed the results of this inspection with R. Freudenberger and other members of your staff. The results of this inspection are documented in the enclosed report.

No violations of more than minor significance were identified during this inspection.

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Eric C. Michel, Chief Projects Branch 2 Division of Fuel Facility Inspection Docket No. 07000027 License No. SNM-42

Enclosure:

As stated cc w/ encl: Distribution via LISTSERV

ML21113A106 SUNSI Non-Sensitive Publicly Available Review Sensitive Non-Publicly Available OFFIC RII/DFFI/PB2 RII/DFFI/PB2 RII/DFFI/PB2 RII/DFFI/PB2 E

NAME T. Sippel N. Peterka A. Alen E. Michel DATE 04/16/21 04/16/21 04/16/21 04/16/21 U.S. NUCLEAR REGULATORY COMMISSION INSPECTION REPORT REGION II Docket Number: 07000027 License Number: SNM-42 Report Number: 07000027/2021001 Enterprise Identifier: I-2021-001-0096 Licensee: Nuclear Operations Group, Inc.

Facility: BWXT Nuclear Operations Group, Inc.

Location: Lynchburg, VA 24505 Inspection Dates: January 01, 2021 to March 31, 2021 Inspectors: A. Alen, Senior Resident Inspector N. Peterka, Fuel Facility Inspector T. Sippel, Fuel Facility Inspector Approved By: Eric C. Michel, Chief Projects Branch 2 Division of Fuel Facility Inspection Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at BWXT Nuclear Operations Group, Inc.,

in accordance with the fuel cycle facility inspection program. This is the NRCs program for overseeing the safe operation of licensed fuel cycle facilities. Refer to https://www.nrc.gov/materials/fuel-cycle-fac.html for more information.

List of Violations No violations of more than minor significance were identified.

Additional Tracking Items None.

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REPORT DETAILS PLANT STATUS During the inspection period, routine fuel manufacturing operations and maintenance activities were conducted in the fuel processing areas, Uranium Recovery (UR) facility, and in the Research and Test Reactors (RTR) facility.

INSPECTION SCOPES Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Inspections were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2600, Fuel Cycle Facility Operational Safety and Safeguards Inspection Program. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

SAFETY OPERATIONS IP 88015 - Nuclear Criticality Safety 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 (10 CFR) 70, Domestic Licensing of Special Nuclear Material, including 70.24, 70.61, and 70.62; Chapter 5, Nuclear Criticality Safety, of the facilitys license application; and applicable licensee procedures.

Criticality Analysis (IP Section 02.01)

The inspectors interviewed licensee NCS staff and reviewed nuclear criticality safety evaluations (NCSEs), and supporting documents, to verify compliance with Title 10 of the Code of Federal Regulations (CFR) 70, "Domestic Licensing of Special Nuclear Material,"

and applicable sections of the license application. Specifically, the inspectors interviewed licensee NCS engineers and reviewed the following documents related to the Lynchburg Technology Center (LTC), the container storage facility, and other operations:

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  • NCS-PA-27-00001, "Nuclear Criticality Safety Evaluation of Element Operations," Rev. 0
  • NCS-PA-42-00001, "Nuclear Criticality Safety Evaluation for 235R001 Shipping Container Storage and Handling Core Assembly, the Container Storage Facility, and the Railyard Storage Building," Rev. 0, including the review of accident sequences CSBR-1, CSBR-7, which cover various rack collapse and loss of spacing scenarios, and reviewing the basis for why the licensee screened certain accident sequences as not credible.
  • NCS-PA-37-00005, "Nuclear Criticality Safety Process Analysis of Higher Tier Vertical Operations," Rev. 0, including the review of what-if analysis, normal, credible abnormal, and non-credible accident sequences.
  • NCS-TR-00049, "Nuclear Criticality Safety Technical Reference for Higher Tier Pickling," Rev. 0, because it contained a variety of calculations and information supporting the licensee's evaluation of criticality accident sequences in NCS-PA-37-00005.
  • NCS-TR-00055, "Nuclear Criticality Safety Technical Report for the Container Storage Facility, 235R001 Shipping Container, and Supplemental Core Calculations," Rev. 0, because it contained a variety of calculations and information supporting the licensee's evaluation of accident sequences and items relied on for safety (IROFS) in NCS-PA-42-00001.

Criticality Implementation (IP Section 02.02)

The inspectors selected engineered and administrative controls from the licensees integrated safety analysis (ISA) summary and reviewed process and system descriptions, drawings, plant walkdowns, and operator interviews to verify that the controls were implemented in accordance with applicable requirements in the license application. Specifically, the inspectors interviewed licensee staff and reviewing the following controls associated with the NCSEs listed above:

  • Passive engineered spacing control IROFS in the container storage facility,
  • administrative mass control IROFS in the LTC, and
  • administrative piece count and poison control IROFS for higher tier immersion operations.

Criticality Operational Oversight (IP Section 02.03)

The inspectors assessed the NCS staffs oversight of plant operators, procedures, and operations of systems involving special nuclear material to verify compliance with 10 CFR 70 and applicable sections of the license application. Specifically, the inspectors performed the following activities:

  • Interviewed LTC staff concerning criticality hazards and control methods including monitoring for long-term accumulations,
  • observed a licensee NCS engineer conduct a weekly audit of higher tier operations and reviewed the resulting audit report, and
  • interviewed higher tier immersion operators concerning criticality hazards and control methods including the use of poison fixtures during operations.

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Criticality Programmatic Oversight (IP Section 02.04)

The inspectors reviewed NCS program procedures, and audits to verify compliance with 10 CFR 70 and applicable sections of the license application. Specifically, the inspectors interviewed licensee NCS staff and reviewed the following documents:

  • Most recent external audit of the licensee's NCS program which was documented in the 2020 Triennial Assessment Report dated October 2020.
  • Most recent revision to the licensee's procedure for maintaining and testing their criticality accident alarm system (CAAS), RP-07-103, "Maintaining and Testing the CIDAS MkXI Criticality Monitoring System," Rev. 8.

Criticality Incident Response and Corrective Action (IP Section 02.05)

The inspectors reviewed the licensee's CAAS and corrective action program (CAP) to verify compliance with 10 CFR 70 and applicable sections of the license application. Specifically, the inspectors reviewed documents, and interviewed licensee staff concerning the following:

  • Recent NCS events, their associated corrective actions, and the reportability determination documented by licensee NCS staff including corrective action reports CA202001190, CA202001745, CA202001784, CA202100033,
  • recent CAAS maintenance records and issues including corrective action commitment COM-86190, and
  • recent NCS evacuation drill records and performance for 2018 and 2019.

IP 88135.02 - Plant Status The inspectors routinely conducted walkdowns of licensee areas, observed operators, material control and accounting and security force personnel, inspected postings and licensee guidance documents, interviewed plant personnel, and discussed the results of operational and shift turnover meetings to gain insight into the status of facility activities, risk-inform the selection and implementation of the appropriate core inspection procedures, and ensure compliance with license and regulatory requirements.

Plant Tours (IP Section 03.01)

The inspectors performed weekly tours of plant operating areas housing special nuclear material (SNM) to verify that licensed activities were conducted safely and in compliance with the license 10 CFR 70.

Status Meetings (IP Section 03.02)

The inspectors, on a routine basis, attended and reviewed the results of scheduled licensee meetings to determine plant status and awareness of site activities so that inspection resources were appropriately focused on those activities with the higher safety significance.

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Record and Log Reviews (IP Section 03.03)

The inspectors reviewed selected records and logs to assure they were developed, maintained, and reported as required by applicable license and regulatory requirements.

Identification and Resolution of Problems (IP Section 03.05)

The inspectors reviewed selected issues to determine if the licensee was entering equipment, human performance, and other performance issues in a formalized program to identify, track and assure correction of safety and safeguard significant problems in accordance with 10 CFR 70.62(a)(3) and applicable license requirements.

  • CA 2020-1157, SNM-bearing container inadvertently dropped. Incident date 08/13/2020. Report date 03/01/2021.
  • CA 2020-1190, Component over-pickled. Incident date 08/15/2020. Report date 01/25/2021.
  • CA 2020-1716, UR annular waste tanks' sight glass (IROFS) degraded. Incident date 12/02/2021. Report date 03/02/2021.
  • CA 2020-1745, Daily assays for area waste drums. Incident date 12/02/20. Report date 03/01/2021.
  • CA 2021-0033, CAAS fault on 'Blue Loop'. Incident date 01/07/2021. Report date 03/10/2021.
  • CA 2021-0085, UR wet scrubber loss of primary fan ventilation. Incident date 01/16/21. Report date 03/10/2021.

Event Review (IP Section 03.06)

The inspectors reviewed the plant event listed below to determine if the event warranted the use of formal event review criteria and to evaluate the licensees response was, as applicable, in accordance with 10 CFR Parts 40.60 (source material), 70.50 (mainly radiological events), 70.52 (criticality and safeguards events), 71.95 (transportation events),

73.71 (safeguards events), and 20.2201, 20.2202, and 20.2203 (radiological and environmental events).

  • CA 2021-0024, Evaluation of fire hazard associated with the process exhaust ventilation of Specialty Fuel Facility (SFF) workstation furnace, WS-300, due to potential oxygen in-leakage. Report date 03/10/2021.

Audits (IP Section 03.07)

The inspectors reviewed the internal audit listed below to determine whether they have been performed in accordance with the license application.

  • Radiation Protection Audit - 4th Quarter 2020 Radiation Work Permit (RWP) (IP Section 03.09)

The inspectors reviewed and observed the RWP listed below to determine whether it contained the information required by Chapter 4, Radiation Safety; of the license application, the Radiation Protection Manual; and implementing procedures:

  • RWP 21-00051, "Bays 14A and 15A Glovebox Cleanout," Rev. 1 6

Annual Security and Emergency Preparedness Drills/Exercises (IP Section 03.10)

The inspectors observed the licensees performance during the security force-on-force (FOF) tactical response exercise evolution listed below to determine it was implemented in accordance with 10 CFR 73.46(b)(9):

  • FOF tactical response exercise conducted on March 24, 2021.

IP 88135.04 - Resident Inspection Program Operational Safety The inspectors evaluated whether the material condition and as-found configuration of selected site structures, systems, and components, documentation, personnel, and IROFS to verify compliance with 10 CFR Part 70, the license, the safety analysis report (SAR) and/or license application, and licensee policies and procedures; and determine whether they are appropriate, available, and reliable to protect worker and public safety during normal, off-normal, and accident conditions.

Operations Safety Walkdown (IP Section 03.01)

The inspectors evaluated the operational safety of the systems, sub-systems, and/or process listed below associated with SAR 15.38, "Core Assembly, Disassembly, and Railyard Storage," Rev. 39.

  • Fuel cell assembly process
  • Power unit assembly process
  • Area storage SSCs IP 88135.05 - Resident Inspection Program Fire Protection (Annual/Quarterly)

The inspectors evaluated the operational status and material condition of fire protection systems, structures, and components (SSCs) to verify compliance with the fire protection program as described in Chapter 7, Fire Safety of the license application and the National Fire Protection Association 801, Standard for Fire Protection for Facilities Handling Radioactive Materials, as required.

Fire Area Walkdown (IP Section 03.01)

The inspectors walked down and evaluated the fire area(s) listed below:

  • Vault 7, Sample Room, and Shipping and Receiving
  • Railyard Storage Building IP 88135.17 - Permanent Plant Modifications The inspectors evaluated implementation of the configuration management system for facility changes or modifications to ensure that safety-related systems, structures, and components (i.e., IROFS or other credited safety controls) could adequately perform their intended safety function and that changes did not adversely impact the operability and safety of the facility.

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IP 88135.19 - Post Maintenance Testing The inspectors evaluated post-maintenance test activities to verify compliance with license application Chapter 11, Management Measures, and test procedures and/or work order (WO) instructions to confirm functional capability of the IROFS and/or safety control(s) following maintenance.

Post-Maintenance Testing (IP Section 03.01)

The inspectors reviewed the three post-maintenance tests listed below. Tests were either observed directly or test results were reviewed.

  • SER 20-004, "Uranium Recovery New Fire Protection Sprinklers Hydrostatic, Pneumatic, and Flow Switch Pre-Operational Test," conducted on December 23, 2020, and January 8, 2021
  • WO 20296557, "Replacement of SFF Workstation (WS) 145 Cooling Water Temperature Controller IROFS," conducted on January 15, 2021
  • WO 20297287, "SFF WS-145 Process Ventilation Pressure/Gauge IROFS Troubleshooting," conducted on January 22, 2021 IP 88135.22 - Surveillance Testing The inspectors evaluated IROFS and safety controls that required periodic surveillance and/or calibration tests to ensure they were available and reliable to perform their function when needed, to comply with license application Chapter 11, Management Measures, and the performance requirements of 10 CFR 70.61 and 70.62, and to maintain their operational readiness consistent with the Integrated Safety Analysis.

Surveillance and Calibration Testing (IP Section 03.01)

The inspectors reviewed the surveillance and/or calibration tests listed below. Tests were either observed directly or test results were reviewed.

  • MP-4041, "Quarterly Boron Sampling of RTR Arc-Melt Furnace Cooling Water," conducted on February 4 and 5, 2021 INSPECTION RESULTS No violations of more than minor significance were identified.

EXIT MEETINGS AND DEBRIEFS The inspectors verified no proprietary information was retained or documented in this report.

  • On April 22, 2021, the inspectors presented the integrated inspection results to R.

Freudenberger and other members of the licensee staff.

  • On January 28, 2021, the inspectors presented the nuclear criticality safety inspection results to B. J. Burch and other members of the licensee staff.

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DOCUMENTS REVIEWED Inspection Type Designation Description or Title Revision or Procedure Date 88015 Calibration NOG-L CIDAS MkXI Criticality System Calibration 12/28/2020 Records Drawings JJA1_1000E Container Storage Building First Floor Plan, Enlarged Plans, 04/14/2016 and Details JJA1_1001E General Arrgmnt. Container Storage Bldg. FLR Plan, Mezz 04/14/2016 Plan, Sections & Details Engineering NCS-2020-071 NCS Safety Analysis for SER 20-010, Phase 1 to Increase 10/21/2020 Evaluations the NCS Mass Limit for TRISO Workstation 250/300 NCS-2020-116 NCS Safety Concern of Inline Monitor #2 IROFS per 12/08/2020 CA202001546 NCS-2020-120 NCS Justification Analysis for SER-043, Phase 1, Phase 2, 12/02/2020 and Phase 3 to Install additional Weld Boxes NCS-2020-124 NCS Safety Concern of Waste Drums in Filler Area 12/21/2020 CA202001745 NCS-2021-001 NCS Safety Concern for Over Pickle Event - CA202001190 01/21/2021 Miscellaneous N/A 2018 Evacuation Drill Results 06/29/2018 N/A 2019 Evacuation Drill Results 08/27/2019 RP-07-103 Form Functional Test of Speakers and NAWLS 12/30/2020 4

Procedures NCSE-2 Nuclear Criticality Safety Analyses & Qualify Assurance Rev. 47 Reviews QWI 02.1.03 Integrated Safety Analysis Methodology Rev. 18 QWI 14.1.10 Safety Evaluation of Unusual Incidents Rev. 18 QWI 15.1.8 Packaging and Measuring Scrap and Waste Rev. 13 RP-07-103 Maintaining and Testing the CIDAS MkXI Criticality Rev. 8 Monitoring System 88135.02 Corrective Action 2021-0030 Fuel dummies in transport cart in excess of NCS posting 03/10/2021 Documents limit. Incident 1/8/2021 Corrective Action 2020-1716 Uranium Recovery Annular Waste Tanks' Sight Glass 03/02/2021 Documents Degraded, Incident 12/02/2020 Resulting from 2020-1745 Daily assays for area waste drums not in accordance with 03/01/2021 Inspection procedures, Incident date 12/02/20 Drawings 14AE7_1000 Scrubber Replacement Power Distribution Block Diagram Rev. 1 9

Inspection Type Designation Description or Title Revision or Procedure Date J2183GH01 Triple SMS4/3KO/15A Switchmode Power Supply System Rev. 2 Arrangement J3234HC01 Circuit Diagram 24V DC UPS System - Blue and Yellow Rev. 1 Systems J3234HC03 Circuit Diagram Rectifier Cradle Rev. 0 UPRR 10060 Workstation 300 Piping & Instrumentation Diagram (P&ID) Rev. 02 UPRR-30138 Recovery Scrubber Makeup and Water/Drain P&ID Rev. 4 UPRR-30139 Recovery Scrubber Recirculation Line and Sight Glass Rev. 1 Engineering CHG-10041 Switch out Facility Alarm System (FAS) Touchscreen Panel 02/17/2021 Changes N-130 Functional Specification for Recovery Wet Scrubber (SER14-032 Phase 01, Installation and Testing of 14A Recovery Scrubber Rooftop and Electrical Equipment, 01/19/2017)

Engineering NCS-2011-058 NCS Analysis for SER 10-045 Phase 01, "Permanent 05/19/2011 Evaluations Shutdown of Downblend" (U)

NCS-2020-124 NCS Safety Concern of Waste Drums per CA2020-1745 12/21/2020 NCS-2021-001 NCS Safety Concern for Over-Pickle Event 01/21/2021 NCS-2021-007 NCS Safety Concern for Sight Glass in Annular Tank #2 - 01/14/2020 CA202001716 NCS-PA-00021 Nuclear Criticality Safety Evaluation of Low-Level Rev. 2 Radioactive Dry Waste Processes Miscellaneous Conway, Ken C., BWXT NOG-L Radiation Protection 01/18/2021 Manager, letter to Distribution, Re: RP Audits, Inspections, 4th Quarter 2020 N-79 Evaluation of Unusual Incident - CA2021-0024 Completed 01/08/2021 N/A Uranium Recovery Wet Scrubber Alarm Criteria - Ladder Rev. 14 Diagram N/A Emergency Preparedness Committee Informational Package 03/08/2021 NCS Posting 15- </= 55-Gallon Drum Storage Areas Rev. 4 21-002 NCS Posting 15- RTR Plate Cart Rev. 03 23-013 PSC-5630-RPT- Investigation of Damaged Wiring Terminals on Installed Rev. 0 001 CIDAS Panel at BWXT Lynchburg SAR 15.12 Liquid and Solid Waste Handling Processes in Uranium Rev. 83 10

Inspection Type Designation Description or Title Revision or Procedure Date Recovery SAR 15.12 Appendix Rev. 30 SAR 15.14 Scrubber Ventilation and Vacuum System in Uranium Rev. 75 Recovery SAR 15.21 Low-Level Radioactive Waste Processes Waste Operations Rev. 79 SAR 15.21 Appendix Rev. 31 SAR 15.23 Fuel Plate and Element Fabrication Process RTRT Operation Rev. 117 SAR 15.37 Higher Tier Assemblies Rev. 60 SAR 15.5 High-Level Dissolution Process in Uranium Recovery Rev. 142 Procedures OP-0021001 Operating Procedure for Pickling Rev. 90 OP-0061127 Raffinate/Waste Collection System Operation (U) Rev. 18 OP-0061143 Operating Procedure for Uranium Recovery Scrubber Rev. 35 Operation (U)

OP-0061167 Spill and Leak Handling Emergency Procedure Rev. 36 OP-0100110 Handling Scrap and Waste in the Filler Area (U) Rev. 12 OP-1000309 NDA Measurement of Waste and Scrap (U) Rev. 14 QWI 15.1.08 Packaging and Measuring of Scrap and Waste Rev. 13 QWI 17.1.1 Environmental, Safety, Health & Safeguards Audit Program Rev. 12 RP-05 Respiratory Protection Rev. 15 RP-05-001 Respirator Issuance Rev. 21 RP-06 Radiation Work Permit Rev. 14 Work Orders 20241565 Scrubber Recirculation Pump #2 Mechanical Seal Completed Replacement 01/15/2019 20296888 MM1 Crit Room Thermal Scan 01/19/2021 88135.04 Corrective Action 2016-1165 Recommendation/Observations from 2016 3rd Quarter NCS Documents Audit of SAR 15.38, Incident 09/07/2016 2019-1308 Storage Stand Top Slid onto Working Platform, Incident 03/10/2021 09/11/2019 2019-1476 Passive Engineering Control Not in Place as Designed per 03/10/2021 LT-5431, Incident 10/16/2019 Drawings 4AA4_1000 Equipment Floor Plan Rev. 1 LT-4091 Assembly Storage Stand Tool - Detail of Component Storage Rev. 1 Box NNFD-2157 Assembly and Storage Rack Rev. 2 NNFD-2158 Assembly and Storage Rack Rev. 1 11

Inspection Type Designation Description or Title Revision or Procedure Date NNFD-2165 Assembly and Storage Rack Rev. 3 Engineering CHG-0613 Installation of Mechanical Testing Station in Core Assembly Completed Changes 06/16/2016 CHG-2167 Update SAR and Appendix 15.38 Completed 05/31/2017 CHG-3416 Changes to SARs 15.05, 15.06, 15.23, 15.38 per SER 16- Completed 023 Phase 01, CHG-3160, CA20170183 09/26/2017 CHG-4576 Core Assembly Storage Stand Work Platform Completed 11/25/2019 CHG-5549 Storing Cores in Core Assembly Stands Completed 12/03/2018 CHG-6207 Core Assembly Storage Stand Modifications Completed 11/21/2019 CHG-6717 Core Assembly ID OP Update - Control Rod Transfer 272- Completed 214 07/25/2019 CHG-7469 Proposed Repairs for Core Assembly Storage Stand Bolt Completed Holes 06/25/2020 SER 16-023 Re-Assemble and Relocate 2-Tier Horizontal Rack 11/07/2018 Miscellaneous SAR 15.38 Core Assembly, Disassembly, and Railyard Storage Rev. 39 Procedures OP-0170504 Operating Procedure for Implementing Free Draining Rev. 3 Controls for Components 88135.05 Drawings 17MA1_1001E Floor Plan Rev. 15 Engineering CR-1019264 Changes to Vault 7 Operations OP 12/21/2004 Changes CR-1021002 Changes to Vault 7 Operations OP 06/02/2005 Engineering HS-2001-002 Fire Protection in the Vault 7 and Mitigating Factors 07/09/2001 Evaluations NCS-2001-299 Increasing the Combustible Loading in the New Storage 12/16/2004 Vault NCS-2002-119 Nuclear Safety Release for SER 00-066, Pre-Operational 06/06/2002 Testing Requirements Fire Plans N/A Pre-Fire Plan, Map Section 12A 03/07/2017 Miscellaneous FSR-06 Facility Siting Review 6 Rev. 4 ISAP 01-00008 Fire Historical Data Review for Storage PHA Rev. 0 ISAP 01-00018 Fire Loading Analysis, Storage, Sample Room, and Shipping Rev. 0 and Receiving Area, SAR 15.33 ISAP 01-00078 Fire Protection Calculations for the New Storage, SAR 15.33 Rev. 1 ISAP 01-00080 COSMOS Fire Modeling for New Storage, SAR 15.33 Rev. 0 12

Inspection Type Designation Description or Title Revision or Procedure Date SAR 15.33 Vault 7 Operations Rev. 42 Procedures E4-771 Lifting System Checklist Rev. 3 E41-201 Vault 7 Operations Rev. 25 E41-209 Operating Instructions for the Walk Behind Lifting System Rev. 2 PM10050 Preventive Maintenance Instructions - BPR/RICO Lift Rev. 1 Inspection Report - Mechanical PM40031 Preventive Maintenance Instructions - Lift Inspection Rev. 1 Month Electrical Work Orders 20123596 Lift Truck LIF175 is Leaking Fluid Completed 07/20/2012 20274558 SC Lift Truck LIF219 6-Month Mechanical Inspection Completed 01/17/2020 20274559 SC Lift Truck LIF219 6-Month Electrical Inspection Completed 01/20/2020 20275233 SC Lift Truck LIF175 6-Month Mechanical Inspection Completed 01/17/2020 20275234 SC Lift Truck LIF175 6-Month Electrical Inspection Completed 01/21/2020 20284671 SC Lift Truck LIF219 6-Month Mechanical Inspection Completed 06/25/2020 20284672 SC Lift Truck LIF219 6-Month Electrical Inspection Completed 07/24/2020 20285447 SC Lift Truck LIF175 6-Month Mechanical Inspection Completed 08/04/2020 20285448 SC Lift Truck LIF175 6-Month Electrical Inspection Completed 07/24/2020 20295094 SC Lift Truck LIF219 6-Month Mechanical Inspection Completed 01/26/2021 20295095 SC Lift Truck LIF219 6-Month Electrical Inspection Completed 01/19/2021 20295750 SC Lift Truck LIF175 6-Month Mechanical Inspection Completed 01/26/2021 20295751 SC Lift Truck LIF175 6-Month Electrical Inspection Completed 01/20/2021 88135.19 Calibration Certificate No. SFF WS-145 OMEGA RTD Temperature Controller IROFS 07/16/2020 13

Inspection Type Designation Description or Title Revision or Procedure Date Records 417609 (CS-01889)

Certificate No. SFF WS-145 OMEGA RTD Temperature Controller IROFS 07/16/2020 417613 (CS-00505)

Certificate No. SFF WS-145 OMEGA RTD Temperature Controller IROFS 07/16/2020 417675 (CS-00641)

Certificate No. SFF WS-145 OMEGA RTD Temperature Controller IROFS 01/07/2021 423504-2 (CS-05277)

Certificate No. SFF WS-145 OMEGA RTD Temperature Controller IROFS 01/07/2021 423504-3 (CS-05278)

Certificate No. SFF WS-145 OMEGA RTD Temperature Controller IROFS 01/07/2021 423504-4 (CS-05279)

Corrective Action 2020-1209 SFF WS-145 Ventilation Pressure/Gauge Switch Exceeded 12/18/2020 Documents Calibration Date, Incident 08/13/2020 Miscellaneous N/A OMEGA. 4200A Series RTD Temperature Controller.

Operator's Manual M0051/0793 N/A OMEGA. 4001A, 4002A, 4201A, & 4202A Series Temperature Controllers. Operator's Manual M0049/1299 SAR 15.18 SFF Dry-End Processing SFF Operation Rev. 131 Procedures CSP-0327 Gage/Instrument Calibration Procedure Rev. 5 M42-006 Compliance Documentation of Boron Analysis and Boron July 2018 -

Addition Record - Pulled/Analyzed Samples Between July February 2018 and February 2020 2020 OP-1001828 Operating Procedure for FAS Interlocks and Furnace Testing Rev. 37 QWI 9.1.7 Preventive/Predictive Maintenance and Safety-Related Rev. 12 Controls Testing Program Work Orders 20288879 Replacement of SFF WS-145 Process Ventilation 08/13/2020 Pressure/Gauge Switch IROFS 88135.22 Miscellaneous SAR 15.22 Research Test Reactor and Targets Fuel Powder and Rev. 98 Compact Processes Procedures M42-058 Boric Acid Addition Worksheet for Pre-Mix and Pre-Made 02/08/2021 Solution (LTC Lab. Sample No. 485)

M42-058 Boric Acid Addition Worksheet for Pre-Mix and Pre-Made 02/08/2021 Solution (Chem. Lab. Sample No. 486)

OP-1001075 RTRT Arc-Melting Coolant - Poison Instructions (U) Rev. 7 14

Inspection Type Designation Description or Title Revision or Procedure Date Work Orders 20270452 SC Boron Analysis/Add CHL200 3Mon RTRTO 10/25/2019 20275172 SC Boron Analysis/Add CHL200 3Mon RTRTO 01/27/2020 20280439 SC Boron Analysis/Add CHL200 3Mon RTRTO 04/23/2020 20285357 SC Boron Analysis/Add CHL200 3Mon RTRTO 07/29/2020 20290660 SC Boron Analysis/Add CHL200 3Mon RTRTO 10/22/2020 20295488 SC Boron Analysis/Add CHL200 3Mon RTRTO 02/01/2021 15