ML21210A029

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Global Nuclear Fuel Americas, L.L.C. (GNF-A) - Integrated Inspection Report 07001113/2021002
ML21210A029
Person / Time
Site: 07001113
Issue date: 07/28/2021
From: Robert Williams
NRC/RGN-II/DFFI
To: Nay D
Global Nuclear Fuel - Americas
References
IR 2021002
Download: ML21210A029 (20)


Text

July 28, 2021 Mr. Doug Nay Plant Manager GLOBAL NUCLEAR FUEL-AMERICAS, L.L.C 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. (GNF-A) - INTEGRATED INSPECTION REPORT 07001113/2021002

Dear Mr. Nay:

On June 30, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Global Nuclear Fuel-Americas, L.L.C. (GNF-A) and discussed the results of this inspection with Brad Beard 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/

Robert E. Williams, Jr., Chief Projects Branch 1 Division of Fuel Facility Inspection Docket No. 07001113 License No. SNM-1097

Enclosure:

As stated cc w/ encl: Distribution via LISTSERV

ML21210A029 X Non-Sensitive X Publicly Available X SUNSI Review Sensitive Non-Publicly Available OFFICE RII/DFFI RII/DFFI NAME M. Ruffin R. Williams DATE 7/27/2021 7/28/2021 U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number: 07001113 License Number: SNM-1097 Report Number: 07001113/2021002 Enterprise Identifier: I-2021-002-0120 Licensee: GLOBAL NUCLEAR FUEL-AMERICAS, L.L.C Facility: Global Nuclear Fuel-Americas, L.L.C. (GNF-A)

Location: Wilmington, NC Inspection Dates: April 12, 2021 to April 23, 2021 Inspectors: B. Adkins, Sr. Fuel Facility Projects Inspector G. Goff, Fuel Facilities Inspector T. Sippel, Fuel Facility Inspector P. Startz, Fuel Facilities Inspector Approved By: Robert E. Williams, Jr., Chief Projects Branch 1 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 Global Nuclear Fuel-Americas, L.L.C.

(GNF-A), 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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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 inspection period, normal production activities at the facility were ongoing.

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 88015 - Nuclear Criticality Safety The inspectors evaluated selected aspects of the licensees Nuclear Criticality Safety program to verify compliance with selected portions of 10 CFR 70, including 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 staff and reviewed nuclear criticality safety analyses (CSA) and associated assumptions and calculations to verify compliance with 10 CFR 70 and applicable sections of the license application, including 5.4.2 and 5.4.4. Specifically, the inspectors interviewed licensee staff and reviewed the following CSAs:

  • CSA 407.00.100, "Rod Processing," Rev. 3, including the review of accident sequences 4070.1 to 4070.18, which cover various scenarios that the licensee determined to be not credible, as well as sequences 4074.1 to 4074.7, for the Rod Storage Cabinets
  • CSA 407.00.200, "Rod Processing Appendix," Rev. 3, which was reviewed because it contained a variety of calculations and information supporting the licensee's evaluation of criticality accident sequences in CSA 407.00.100, and the technical basis for the IROFS established for Rod Processing
  • The inspectors walked down risk significant portions of the Rod Processing Area (Nodes 407 and 506), including the Rod Storage Cabinets
  • The inspectors also reviewed the recently issued Validation Report (Rev. 3.1) to verify that the change to the USL did not negatively impact safety 3

Criticality Implementation (IP Section 02.02)

The inspectors selected passive engineered and administrative controls from the licensees integrated safety analysis (ISA) summary to verify proper implementation through a review of process and system descriptions, safety basis calculations, plant walkdowns, and interviews to verify compliance with 10 CFR 70 and applicable sections of the license application, including 5.4.2.1 and 5.4.2.3. Specifically, the inspectors interviewed licensee staff and reviewed the following controls, and their management measures, associated with the Rod Processing area:

  • IROFS 407-07, "Process Equipment Barrier - Rod Storage Cabinet." A passive engineered control which the inspectors observed, and reviewed the related calculations, training document, and the most recent surveillance record
  • IROFS 407-08, "Rod Storage Cabinet - Safe Geometry." A passive engineered control which the inspectors observed, and reviewed the related calculations, training document, the most recent surveillance record, and related procedural requirements
  • IROFS 506-05, "Process Equipment Barrier - Rod Storage Cabinet." A passive engineered control for which the inspectors reviewed the related calculations, training document, and the most recent surveillance record
  • IROFS 506-06, "Rod Storage Cabinet - Safe Geometry." A passive engineered control for which the inspectors reviewed the related calculations, training document, the most recent surveillance record, and related procedural requirements
  • The inspectors reviewed portions of QRA 407/506, "Fabrication - UO2/Gad Rod Processing," including the description of applicable processes, IROFS, management measures applied to IROFS, and accident sequences Criticality Operational Oversight (IP Section 02.03)

The inspectors assessed the Nuclear Criticality Safety (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, including 5.1.3, 5.1.4.1, 5.3.2.2, 5.3.2.4, and 11.6. Specifically, the inspectors performed the following activities:

  • Reviewed training documents (TDs) related to IROFS in the 407 and 506 Nodes, and interviewed operators in these areas
  • Accompanied a licensee NCS engineer performing a periodic observation of passive IROFS
  • Interviewed licensee NCS staff concerning weekly audits (Nuclear Safety Audits) and reviewed the 2021-2022 Audit Schedule and recent audit records
  • Reviewed and discussed the audit findings recorded in the audit records and condition reports written to document issues
  • Interviewed NCS engineers concerning the incorporation of NCS IROFS requirements into procedures and reviewed operating procedures 4

Criticality Programmatic Oversight (IP Section 02.04)

The inspectors reviewed NCS program procedures and NCS staff qualifications to verify compliance with 10 CFR 70 and applicable sections of the license application, including 5.3.2.1. Specifically, the inspectors interviewed licensee NCS staff and reviewed documents concerning the following:

  • NCS engineer qualification records
  • NCS Program procedures, including WI-27-104-15, "NCS Calculation Methods and Verification," Rev. 4, which had recently been revised
  • Interviewed NCS staff concerning the NCS review of changes, including changes to operating procedures that may affect NCS, and changes to the facility Criticality Incident Response and Corrective Action (IP Section 02.05)

The inspectors reviewed entries in the licensees corrective action program (CAP) to verify compliance with 10 CFR 70 and applicable sections of the license application, including 11.7. Specifically, the inspectors reviewed documents, and interviewed licensee staff concerning the following:

  • CR 36339, and associated documentation, for the licensee's response to the 2/26/21 SCALE User Notification of a cross section error concerning the h-poly material. The inspectors interviewed the licensee NCS manager and Senior NCS staff concerning the licensee's response to this error. The licensee revised their validation report to use values calculated using the corrected h-poly material. The inspectors also reviewed the licensee's assessment of the impact of the issue on SCALE calculations that used h-poly.
  • CR 35627, and associated documentation, for an issue associated with the licensee's modeling of certain geometries. The documents reviewed included revisions to CSA 900.00.100, "Homogeneous Uranium Subcritical Limits,"

Rev. 4 and CSA-900.01.100, "Moderation Limits," Rev. 3.

88020 - Operational Safety The inspectors evaluated selected aspects of the licensees Operational Safety program to verify compliance with selected portions of 10 CFR 70, including 70.61, 70.62, and Chapter 11, Management Measures, of the facilitys license application, and applicable licensee procedures.

Identification of Safety Controls and Related Programs (IP Section 02.01)

The inspectors selected specific process areas for inspection based on the safety basis information of the facility, the risk/safety significance of the process areas, the description of plant changes submitted to the NRC, and past plant performance documentation. For the process areas of interest, the inspectors selected a sample of accident sequences in nuclear criticality safety, radiation safety, fire safety, and chemical safety based on 5

the information provided in the integrated safety analysis (ISA) summary. The inspectors conducted a general plant tour of each major plant operating area. The process areas and accident sequences selected for review are listed below:

  • Dry Conversion Process, Accident Sequence 5.3.5.1, Loss of Containment Conversion Area
  • Dry Conversion Process, Accident Sequence 5.3.5.2, Fire in Conversion Room
  • Dry Conversion Process, Accident Sequence 5.3.5.6, Loss of Containment-UF6 Feed Line
  • Dry Conversion Process, Accident Sequence 5.3.5.18, Loss of Containment in the Conversion Room due to Hydrogen Pipe Rupture from Crane Drop Review of Safety Controls and Related Programs (IP Section 02.02)

The inspectors reviewed information related to administrative, engineered, and passive safety controls or items relied on for safety (IROFS) for the accident sequences selected above, including the identification of the licensees assumptions and bounding cases as they apply to each of the selected accident sequences, safety controls, or IROFS. This review was performed to verify that the controls or IROFS were available and reliable to perform their intended safety functions and that the design basis assumptions were reflected in the actual conditions in the field. The specific safety controls selected for review are listed below:

  • IROFS 201-20/UF6 Feed Piping, passive engineered, chemical safety
  • IROFS 202-01/Cold Leak Check, administrative, chemical safety
  • IROFS 202-02/Reactor Hi Pressure Interlock, active engineered, chemical safety
  • IROFS 202-03/Conversion Room System 1 HF Detector Automatic System Shutdown, active engineered, chemical safety
  • IROFS 202-04/Conversion Sense & Flee, administrative, chemical safety
  • IROFS 202-05/Conversion Room System 2 HF Detector Alarms, augmented administrative, chemical safety
  • IROFS 202-25, Process Equipment Barrier (Conversion), passive engineered, chemical safety
  • IROFS 202-28/Conversion Room Crane Admin Control, administrative, fire/chemical safety
  • IROFS 202-31/Conversion Combustible Control Program, administrative, fire/chemical/criticality safety
  • IROFS 900-05, Non-Hydrogenous Fire Suppression, administrative, fire/criticality safety Implementation of Safety Controls (IP Section 02.03)

For the selected safety controls listed above, the inspectors reviewed management measures to verify proper implementation in accordance with 10 CFR 70 Subpart H and 6

applicable sections of the license application. This review was performed to verify that selected safety controls or IROFS were present, available, and reliable to perform their safety function and that the design basis assumptions were reflected in the actual conditions in the field. The inspectors conducted the following activities to verify the implementation of selected safety controls:

  • walked down the dry conversion process (DCP) including the control room, conversion room, reactor, uranium hexafluoride (UF6) piping, hydrogen monitors, and hydrogen fluoride (HF) detectors to verity implementation of IROFS listed in Section 02.02
  • reviewed operations procedure OP 202.00.201 to verify proper implementation of IROFS 202-03, 202-05 202-26, 202-27, and 202-28
  • observed a surveillance of IROFS 201-24 and 201-25, DCP Line 2 cold trap weight interlocks
  • walked down the DCP, conversion room, reactors, UF6 vaporization, powder operations, and supporting areas to verify that process equipment barriers were maintained in accordance with IROFS 202-25
  • reviewed DCP operations temporary operating procedure CR-29130 to verify maintained implementation of IROFS 202-04 during the installation of the new DCP Digital Control System, Line 1
  • walked down the conversion room, reactors, UF6 vaporization, and powder operations to verify that the combustible control program was maintained in accordance with IROFS 202-31
  • walked down all moderation-controlled areas including the conversion room, reactors, UF6 vaporization, and powder operations to verify that the non-hydrogenous Fire Suppression requirements were being maintained in accordance with IROFS 900-05 Safety Control Support Programs (IP Section 02.04)

The inspectors assessed additional management measures that support the availability and reliability of the selected safety controls to verify these were implemented in accordance with 10 CFR 70 Subpart H and applicable sections of the license application. Specifically, the inspectors conducted the following:

  • reviewed completed functional test records for IROFS 202-01, 202-02, 202-03, 202-05, 201-24 and 201-25
  • reviewed IROFS failure and degradation records (condition reports) CR-35277, 36056, 36091, 36100, 36275
  • reviewed audit/self-assessments related to chemical safety and combustible material control
  • reviewed training and qualification documents for two DCP control room operators
  • reviewed active temporary operating procedures (TOP)-29128, "Additional Sample Storage in DCP Sample Room; and TOP-29130 Cold Trap Calibration Activity Logs LS1331.04
  • interviewed DCP control room operators about the implementation of TOP-29130 Cold Trap Calibration Activity
  • reviewed qualitative risk assessment QRA-202, DCP Conversion 7
  • reviewed housekeeping issues that degrade the Combustible Control Program as required by IROFS 202-31
  • reviewed completed functional test records for IROFS 202-01, 202-02, 202-25
  • observed DCP shift turnover on 04/12/21 and attended plan of the day meetings on 04/13 and 04/14/21
  • reviewed Training Document (TD) 202-25, Revision 1, Conversion Sense and Flee, for proper training currency
  • reviewed TD 202-01, Revision 1, Cold Leak Check, for proper training currency
  • reviewed TD 202-02, Revision 2, Reactor Vessel, for proper training currency RADIOLOGICAL CONTROLS 86740 - Inspection of Transportation Activities The inspectors evaluated select aspects of the licensees Transportation Activities program to determine whether the licensee has established and is maintaining an effective, management-controlled program; to ensure radiological and nuclear safety in the receipt, packaging, delivery to a carrier and, as applicable, the private carriage of licensed radioactive materials; and to determine whether transportation activities are in compliance with the applicable Nuclear Regulatory Commission 10 CFR Parts 20 and 71 regulations and Department of Transportation (DOT) (49 CFR Parts 171-178) transport regulations.

Preparation of Packages for Shipment (IP Section 02.01)

The inspectors examined the licensees procedures to verify compliance with applicable federal regulations. Specifically, the inspectors reviewed the following:

  • OP 2000.01
  • OP 2000.10
  • OP 2000.04.201
  • OP 2000.05.002 Delivery of Completed Packages to Carriers (IP Section 02.02)

The inspectors examined the shipment record for a recent, outgoing shipment to determine that the licensee met package delivery requirements. Specifically, the inspectors reviewed or observed the following:

  • shipping manifest
  • control of custody forms
  • radiological surveys
  • bill of lading
  • that the flatbed trailers used to transport completed packages to a carrier were equipped with the required placarding 8

Receipt of Packages (IP Section 02.03)

The inspectors examined the licensees procedures and records for an incoming shipment to verify compliance with 10 CFR 20.1906 and applicable license requirements. Specifically, the inspectors observed or reviewed the following:

  • OP 1339.01.202
  • OP 1339.01.203
  • OP 2000.04.202
  • GNFV6237250
  • GNFV6237291
  • the licensee opening the seavan (outer shipment container) and removing all new powder containers (NPCs) inside the seavan
  • the radiation safety technicians perform surveys on each NPC
  • all labels and markings on the NPCs
  • the opening of an empty NPC polypack
  • the operator performing the removal and verification requirements of the empty polypacks inside the NPCs
  • the flat bed trailer used for carrying seavans (which contain empty NPCs) to verify proper placarding was available on all four sides of the trailer was per DOT regulations Records and Reports (IP Section 02.04)

The inspectors examined the licensees procedure for recordkeeping and reports to verify compliance with applicable federal regulations. Specifically, the inspectors reviewed the following:

  • shipping manifests
  • bills of lading
  • radiation surveys
  • contamination surveys
  • control of custody forms
  • SARS for the various types of packages utilized by the licensee General License Requirements (IP Section 02.05)

The inspectors reviewed the certificates of compliance used for shipment of radioactive material packages to verify compliance with 10 CFR 71, Subpart C. Specifically, the inspectors reviewed:

  • 9196 for UX-30 packages
  • 9294 for NPC packages
  • 9309 for RAJ-II packages
  • 9362 for DN30 packages 9

Management Controls (IP Section 02.06)

The inspectors reviewed the system of management controls for transportation activities to verify compliance with licensee instructions and procedures. Specifically, the inspectors:

  • reviewed and walked down the IROFS under the jurisdiction of the transportation/logistics department
  • reviewed shipment records for authorization signatures from managers Indoctrination and Training Program (IP Section 02.07)

The inspectors reviewed training documentation for workers involved in transport activities to verify compliance with Chapter 11 of the licensee application. Specifically, the inspectors:

  • reviewed the training records, including HAZMAT, for package handlers/preparers
  • determined that the workers had received and were maintaining their training current
  • noted that the licensee had a computerized system for "locking out" any employee delinquent on training Quality Assurance Program (IP Section 02.08)

The inspectors reviewed the quality assurance documents to verify compliance with the licensees quality assurance program. Specifically, the inspectors:

  • reviewed NQA-2020-007
  • verified by a review of procedure that dents and dings in packages less than one inch in depth are acceptable
  • observed that the packages were not stacked more than five high as required by procedure Audit Program (IP Section 02.09)

The inspectors reviewed the latest audit to verify compliance with 10 CFR 71.137. Specifically, the inspectors:

  • reviewed the most recent internal audit report performed by the Quality Assurance staff
  • confirmed that the audit contained criteria and parameters pertinent to the transportation program
  • noted that concerns and recommendations for improvement were placed into the corrective actions program
  • reviewed the following corrective actions: 34478, 34661, 36575 Procurement and Selection of Packagings (IP Section 02.10) 10

The inspectors examined the licensees packages and certificates of compliance to verify compliance with applicable federal regulations. Specifically, for packaging that was used by the licensee to transport or to deliver licensed material to a carrier for transport, the inspectors walked down the following packages:

  • NPC packages
  • RAJ-II packages Preparation of Packages for Shipment (IP Section 02.11)

The inspectors examined the licensees package markings, documentation, and records to verify compliance with applicable parts of the federal regulations. Specifically, the inspectors reviewed:

Periodic Maintenance of Packagings (IP Section 02.12)

The inspectors examined the licensees procedures and observed activities in the field to verify compliance with applicable parts of the federal regulations. Specifically, the inspectors:

  • reviewed OP 2000.02
  • reviewed OP 2000.03
  • observed refurbishment activities to the inner and outer containers of the RAJ-II containers
  • noted that the workers were fluent in the performance of their job functions
  • viewed the internal arrangements of both the external box and internal box of the RAJ-II packages to verify that cushioning, linings, braces, bolts, and other stabilizing components were in the proper arrangement and were not damaged as per procedure Records, Reports, and Notifications (IP Section 02.13)

The inspectors reviewed the licensees records for recordkeeping and reports to verify that a system is in place to verify compliance with the applicable federal regulations. Specifically, the inspectors reviewed the following:

  • many completed shipping packages in the records retention system over the last 24 months INSPECTION RESULTS No issues were identified.

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

  • On April 15, 2021, the inspectors presented the Operational Safety inspection results to Brad Beard and other members of the licensee staff.

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  • On April 22, 2021, the inspectors presented the NCS and Transportation inspection results to Brad Beard and other members of the licensee staff.

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DOCUMENTS REVIEWED Inspection Type Designation Description or Title Revision or Procedure Date 86740 Corrective Action 34478, 34661, Documents 36575 86740 Miscellaneous CP-13-103 Shipping and Receiving of Radioactive Materials Revision 2.1 86740 Miscellaneous CP-20-100-F02 Equivalency Evaluation 01/02/2019 86740 Miscellaneous CR 29256 Training Document: TD 101-08 UF6 Cylinder Handling Revision 2 Combustible Control Program 86740 Miscellaneous DOT Document Chapter 2.7 - Class 7 - Radioactive material (UN Numbers) 86740 Miscellaneous IROFS - TD 101-05 Visual Inspection of UF6 Cylinders Following an Revision 0 Administrative Off-Normal Event Control 86740 Miscellaneous IROFS - Passive TD 101-02 UF6 Cylinder Revision 0 Engineered Control 86740 Miscellaneous NEDE-33869P RAJ-II Safety Analysis Report Revision 10 86740 Miscellaneous NEDE-33881P NPC Safety Analysis Report Revision 7 86740 Miscellaneous NQA-2020-007 Internal Audit Report 86740 Miscellaneous Radiation Ludlum Model 44-9 Alpha, Beta, Gamma, Detector 01/01/2018 Protection (Scanning RAJ-IIs) 86740 Miscellaneous Training Ongoing training records and requirements for seven (7) workers transportation shipments 86740 Miscellaneous Training Several Certificates of Completion for Training to U.S. Dept. 05/01/2019 of Transportation 49CFR, Part 172, Subpart H and/or International Transportation Regulations for Hazardous Materials/Dangerous Goods for five (5) shipping employees.

86740 Miscellaneous USA/9196/B(U)F- Certificate of Compliance 9196 - (UX30) Revision 30 96 86740 Miscellaneous USA/9294/AF-96 Certificate of Compliance 9294 - (NPC) Revision 9 86740 Miscellaneous USA/9309/B(U)F- Certificate of Compliance 9309 - (RAJ-II) Revision 12 96 86740 Miscellaneous USA/9362/AF-96 Certificate of Compliance 9362 - (DN30) Revision 0 86740 Procedures 0023-HA-2015- Use and Handling of the DN30 Package Revision 5 001-Rev5 13

Inspection Type Designation Description or Title Revision or Procedure Date 86740 Procedures 0023-PA-2015- Inspection Criteria for Regular and Periodical Inspections of Revision 3 016-Rev3 the DN30 Package (Test Instruction) 86740 Procedures OP 1080.70.300 UF6 Cylinder Dock - Process Information Revision 6 86740 Procedures OP 1339.01.202 NPC Powder Pack - Normal Operations Revision 5 86740 Procedures OP 1339.01.203 NPC Powder Pack - Cleanout Revision 00 86740 Procedures OP 2000.01 Shipment of NPC Revision 25 86740 Procedures OP 2000.02 RAJ-II Outer Container Refurbishing Revision 36 86740 Procedures OP 2000.03 RAJ-II Inner Container Refurbishing Revision 30 86740 Procedures OP 2000.04.201 Shipping & Traffic - Shipping Operations Revision 3 86740 Procedures OP 2000.04.202 Shipping & Traffic - Receiving Operations 02 ADMIN 86740 Procedures OP 2000.05.002 Fuel Bundles in RAJ-II Containers - Container Loading and Revision 3 Securing 86740 Procedures OP-2000.10 Shipment of UF6 Material & Containers Revision 17 86740 Radiation GNFV6237250 Incoming Shipment Survey 04/21/2021 Surveys 86740 Radiation GNFV6237291 Incoming Shipment Survey 04/20/2021 Surveys 86740 Shipping Records Record of International Export Memo of Shipment (Invoice, Packing 10/13/2020 Shipment List, Bill of Lading) 88015 Corrective Action CR 35279, CR Various NCS related condition reports Various Documents 35627, CR 35707, Dates CR 36339, CR 36637 88015 Engineering SCALE6.1/KENO-VI Monte Carlo Code Validation Report Rev. 3.1 Evaluations 88015 Engineering CSA 208.00.100 DPC MRA Facility and Powder Containers Rev. 2 Evaluations 88015 Engineering CSA 701.00.200 Decon Appendices Rev. 2 Evaluations 88015 Engineering CSA-407.00.100 Rod Processing Rev. 3 Evaluations 88015 Engineering CSA-407.00.200 Rod Processing Appendix Rev. 3 Evaluations 88015 Engineering CSA-701.00.100 Decon Rev. 2 14

Inspection Type Designation Description or Title Revision or Procedure Date Evaluations 88015 Engineering QRA-407/506 Fabrication - UO2/Gad Rod Processing Rev. 14 Evaluations 88015 Miscellaneous Nuclear Safety Audit Schedule 88015 Miscellaneous FMOMAD NCS IROFS Surveillance Completion Records for Various IROFS 407-07, 407-08, 506-05, and 506-06 Dates 88015 Miscellaneous Bundle Assembly Operator Training Records 88015 Miscellaneous Numerous Nuclear Safety Audit reports Various Dates 88015 Miscellaneous Hot Area Rod Handling Operator Training Records 88015 Miscellaneous TD 407-01 Rod Load Equipment - Free Draining Rev. 0 88015 Miscellaneous TD 407-02 Rod Load Equipment - Safe Geometry Rev. 2 88015 Miscellaneous TD 407-07 Process Barrier - Rod Storage Cabinet Rev. 0 88015 Miscellaneous TD 407-08 Rod Storage Cabinet - Safe Geometry Rev. 3 88015 Procedures CP-27-104 Nuclear Safety Assurance Rev. 2 88015 Procedures WI-18-104-02 Internal Nuclear Safety Audits Rev. 4 88015 Procedures WI-27-104-03 Nuclear Safety Reviews Rev. 4 88020 Calibration FTI 204-01A Kiln Hatch N2 Purge Pressure Alarm PT #2115 2020 Records 88020 Calibration PM-F6P12100- Annual pressure cal for PT12100 kiln/reactor 09/06/2020 Records 06-AN-07, WO #2157777 88020 Calibration PM-F8S12100- Annual verification for current/pressure trip of the Moore high 09/03/2020 Records CALI pressure interlock 88020 Calibration WO#4712618 Monthly Calibration DCP Conversion HF 03/23/2021 Records 88020 Corrective Action 35277 10/20/2020 Documents 88020 Corrective Action 36056 01/24/2021 Documents 88020 Corrective Action 36091 01/20/2021 Documents 88020 Corrective Action 36100 01/29/2021 Documents 15

Inspection Type Designation Description or Title Revision or Procedure Date 88020 Corrective Action 36275 02/20/2021 Documents 88020 Corrective Action CR 11831 08/21/2014 Documents 88020 Corrective Action CR 36100 Nonconformance Assessment Checklist 01/29/2021 Documents 88020 Corrective Action CR 36100 Safety Assessment for Condition Report 36100 01/29/2021 Documents 88020 Corrective Action CR# 36091 IROFS 202-05 activated with incomplete notifications Documents 88020 Corrective Action CR 36712 04/14/2021 Documents Resulting from Inspection 88020 Corrective Action CR 36720 04/15/2021 Documents Resulting from Inspection 88020 Drawings AO 901-922, Conversion Kiln Sub-Assembly 300 Seal Box Inlet Side Revision B 88020 Drawings PO4 1332 Conversion (Line 3) P&I Diagram 2020 88020 Engineering FTI 202-02, Reactor h\High Pressure PT#2100 IROFS function shutting Evaluations Revision 0 off steam and UF6 upon high reactor pressure 88020 Engineering IROFS 202-25 Initiating event analysis of UF6 Containment Barrier failure, Evaluations and 201-20 Section 5.3.5.1 88020 Engineering IRS 201-24 Cold Trap Weight Interlock A 3 Evaluations 88020 Engineering IRS 201-25 Cold Trap Weight Interlock B 3 Evaluations 88020 Engineering IRS 202-02, Requirements Specification for IROFS 202-02 Reactor High Evaluations Revision 1 Pressure Interlock 88020 Engineering IRS 202-03 IROFS 202-03 Conversion Room System 1 HF Detector 1 Evaluations Automatic Shutdown System 88020 Engineering IRS 202-26 East Hydrogen Alarm with Hydrogen Valve Isolation 0 16

Inspection Type Designation Description or Title Revision or Procedure Date Evaluations 88020 Engineering IRS 202-27 West Hydrogen Alarm with Hydrogen Valve Isolation 0 Evaluations 88020 Engineering Kiln Inlet Seal Kiln Seal Assembly 12/28/1995 Evaluations Fabrication #102-244, List # 92084, Revision B 88020 Engineering QRA-202 DCP - Conversion 23 Evaluations 88020 Engineering QRA-203 DCP HF-Recovery 11 Evaluations 88020 Engineering S10.1320 Piping Classification C Evaluations 88020 Engineering TR 202-00 Technical Report Conversion 0 Evaluations 88020 Miscellaneous DCP Control Room Operator Qualification Card for D. Lewis 09/17/2017 88020 Miscellaneous Shur-Shot X-Proof Hydrogen Fluoride Alarm Operations E Manual 88020 Miscellaneous DCP Control Room Operator Qualification Card for D. Lewis 06/05/2014 88020 Miscellaneous Control Room Operator Qualification Card for B. Muncy 06/15/2014 88020 Miscellaneous Global Nuclear Fuel Integrated Safety Analysis Summary 24 88020 Miscellaneous TD 201-20 Training Document: Process Equipment Barrier (UF6 Feed 0 Piping) 88020 Miscellaneous TD 202-03 Training Document: Conversion Room System 1 HF 3 Detector Automatic System Shutdown 88020 Miscellaneous TD 202-05 Training Document: Conversion Room System 2 HF 3 Detector Alarms 88020 Miscellaneous TD 202-28 Training Document: Conversion Room Crane Administrative 2 Control 88020 Procedures Activity Log Cold Trap Calibration, calibrate while cold trap is hot. DCP LS1331.04, cold Trap Revision 8 88020 Procedures CP-20-107 GNF-A Manufacturing Training and Qualification Program 7 88020 Procedures CR-29130 TOP Continuation of the temporary operating procedure 26067 2020 17

Inspection Type Designation Description or Title Revision or Procedure Date and 27058, Line 1, until MARK 4 DCS installation 88020 Procedures FTI 201-24 Cold Trap Weight Interlock A WIT#1440 0 88020 Procedures FTI 201-25 Cold Trap Weight Interlock B - WTSH#1445 0 88020 Procedures FTI 202-03 Conversion Room System 1 HF - AT#2300.10 0.1 88020 Procedures FTI 202-05 Conversion System 2 HF Detection, AT#2301, 02 1.0 88020 Procedures FTI 202-26 East Hydrogen Alarm ASH#2320 1 88020 Procedures FTI 202-27 West Hydrogen Alarm ASH#2321 1 88020 Procedures OP 1300.00.000, Combustible Material Control-DCP, DSR, Powder 2020 Revision 5 Pack/Receipt, and Fire Barriers 88020 Procedures OP 202.00.201 DCP Conversion - Pre-Startup 3 88020 Procedures OP 202.00.201, DCP Conversion Pre-Start 2020 Revision 3 88020 Procedures OP 202.00.208, DCO Conversion, Alarm response & emergency operations 2020 Revision 0 88020 Procedures OP 202.00.209, DCP Conversion, Basic Operator Maintenance 2020 Revision 6 88020 Procedures TD 2002-04, Conversion Sense and Flee Training 2020 Revision 3 88020 Procedures TD 202-02, Reactor Vessel, close steam and UF6 to the reactor upon 2020 Revision 2 high pressure 88020 Procedures TD 202-25 Process Barrier (Conversion), preventing moderator 2020 Revision 1 intrusion/containment of uranium. Reference QRA-202, IROFS 202-02 88020 Procedures TOP 29130 Additional Storage in DCP Sample Room 07/01/2020 88020 Procedures WI-06-100-26 CAA Temporary Operations 3 88020 Self-Assessments GE Power Wilmington Nuclear Energy Audit FMO (Fuel 11/11/2019 Manufacturing Operations) SNM 1097 18