ML21211A517

BWXT Nuclear Operations Group, Inc.-Lynchburg - Integrated Inspection Report 07000027/2021002

ML21211A517
Person / Time
Site:	BWX Technologies
Issue date:	07/30/2021
From:	Eric Michel NRC/RGN-II/DFFI
To:	Bittner J BWXT
References
IR 2021002
Download: ML21211A517 (22)

Text

July 30, 2021 Mr. James J. Bittner Vice President and General Manager BWXT Nuclear Operations Group, Inc.

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

SUBJECT:

BWXT NUCLEAR OPERATIONS GROUP, INC. - LYNCHBURG -

INTEGRATED INSPECTION REPORT 07000027/2021002

Dear Mr. Bittner:

On June 30, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at BWXT Nuclear Operations Group, Inc. - Lynchburg. On July 22, 2021, the NRC inspectors discussed the results of this inspection with you 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

ML21211A517 x Non-Sensitive x Publicly Available x SUNSI Review Sensitive Non-Publicly Available OFFICE RII/DFFI/PB2 RII/DFFI/PB2 RII/DFFI/PB1 RII/EICS RII/DFFI/PB2 RII/DFFI NAME T. Sippel A. Alen J. Rivera Ortiz D. Edwards E. Michel N. Pitoniak DATE 7/22/21 7/22/21 7/22/21 7/22/21 7/22/21 7/29/2021 U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number: 07000027 License Number: SNM-42 Report Number: 07000027/2021002 Enterprise Identifier: I-2021-002-0039 Licensee: BWXT Nuclear Operations Group, Inc.

Facility: BWXT Nuclear Operations Group, Inc. - Lynchburg Location: Lynchburg, VA 24505 Inspection Dates: April 1, 2021 to June 30, 2021 Inspectors: A. Alen, Senior Resident Inspector D. Edwards, Allegations & Enforcement Specialist J. Rivera Ortiz, Sr. Fuel Facility Project 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. -

Lynchburg, 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 Type Issue Number Title Report Section Status WER 07000027/2021-001-00 Concurrent report for OSHA 88135.02 Closed reportable event (EN55220) 2

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 88020 - Operational Safety The inspectors evaluated selected aspects of the licensees operational safety 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, 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 (NCS), fire safety, and/or chemical safety based on the information provided in the integrated safety analysis (ISA) summary and safety basis documentation. The process areas and accident sequences selected for review are listed below:

• UR Process o NCS and chemical/fire safety accident sequences for main scrubber and wet exhaust ductwork

• Specialty Fuels Fabrication (SFF) Process o NCS and chemical/fire safety accident sequences for dry-end processing operation 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 3

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:

• UR Process: Main Scrubber and Wet Exhaust Ductwork o geometry and spacing control of scrubber components o scrubber ductwork inspections and surveys for mass control o scrubber recirculation tank inspections for mass control and tank level for moderation control o configuration of scrubber overflow lines and air inlets for moderation control o scrubber system ventilation to the high-level dissolution process for hydrogen concentration control o high-level dissolution process shutdown for hydrogen concentration control o high-level dissolution process shutdown with loss of power o high-level dissolution process mass control when loading o hydrogen detectors alarms and interlocks for hydrogen concentration control o activation of backup scrubber fan for hydrogen control in high-level dissolution process in case of loss of power

• SFF Process: Dry-End Processing Operation o leak testing of safety valves for moderation control in finishing furnace o interlock testing of finishing furnace for moderation control o liquid level alarm functionality testing for moderation control o mass and spacing control of finishing furnaces o mass control of particulate filters o sensor vitality checks of various gases 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 and 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:

• UR Process IROFS:

o reviewed maintenance plans (MPs) documenting functional testing and preventive maintenance of selected IROFS o conducted walkdowns of the UR process to verify that selected IROFS were present and performed as intended o reviewed calculation for hydrogen generation in high-level dissolution process to identify assumptions and boundary conditions for scrubber ventilation 4

o reviewed procedures and results of inspection and cleaning of UR process ductwork o reviewed operating procedures (OPs) for UR main scrubber operation to verify that IROFS were implemented in the procedure o reviewed results of annual duct surveys in UR o reviewed results of ventilation fan testing for UR main scrubber o observed implementation of UR ventilation system airflow testing (MP-2411) o walked down and discussed functional testing and calibration of hydrogen detectors in UR (MP-1465) o walked down and discussed functional testing and preventive maintenance of primary and backup fans for UR main scrubber

• SFF Process IROFS:

o reviewed MPs documenting functional testing and preventive maintenance of selected IROFS o conducted walkdowns of the SFF process to verify that selected IROFS were present and performed as intended o walked down and discussed functional testing and calibration of hydrogen chloride, hydride, organic vapor, chlorine detectors (MP-2540, MP-2541, MP-2542, MP-2544, and MP-2550) o walked down and discussed functional testing and preventive maintenance of wiring for connection integrity and degradation per commitment #28096 o walked down and discussed functional testing and preventive maintenance for SFF WS300 o walked down and discussed functional testing and preventive maintenance of test valve fir the finishing furnace o reviewed, walked down, and discussed with licensee personnel operating procedures for SFF to verify IROFS were implemented in the procedure o walked down and reviewed NCS postings for mass and spacing control 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 and applicable sections of the license application. Specifically, the inspectors conducted the following:

• reviewed training and qualification experience for three management positions to verify compliance with the minimum qualifications requirements in the license

• reviewed training plans and a sample of training plan completion for UR and SFF operators

• reviewed a sample of audits and self-assessments in the operations area

• reviewed a sample of problems entered into the corrective action program related to IROFS issues to verify that corrective action management measures were consistent with the license requirements 5

• reviewed and discussed with licensee personnel compensatory measure NCS-2021-024, Justification for Continued Operations of SFF Work Station 140 Following CA202100293 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 and 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.

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 2021-0224, FAS gas detector failed bump test, incident February 17, 2021, report date April 8, 2021

• CA 2021-0293, SFF workstation 140 furnace retort (i.e., NCS safety control) found broken, incident March 2, 2021, report date June 25, 2021

• CA 2021-0408, 'out-of-service' uranium-235 counter instrument used to assign U-235 contents (i.e., NCS safety control) to a waste retention tank, incident March 24, 2021, report date June 25, 2021

• CA 2021-0447, SFF workstation 145 coolant high-temperature interlock controller (IROFS) readout drifting low, incident date January 6, 2021, report date June 23, 2021 6

• CA 2021-0648, RTR high flux isotope reactor (HFIR) plate furnace over-temperature interlock (i.e., management measure) could not be performed as written, incident May 6, 2021, report date June 1, 2021

• CA 2021-1784, vessel solution not sampled (NCS safety control) prior to draining, incident December 17, 2020, report date June 25, 2021 Event Review (IP Section 03.06)

The inspectors reviewed the plant events listed below to determine if the events warranted the use of formal event review criteria and to evaluate the licensees response was 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 2021-0407, surface contamination noted on a treatment plant solids waste drum during offsite disposal facility receipt surveys on March 22, 2021

• CA 2021-0481, RTR encapsulated fuel cladding breached during sizing operation on April 6, 2021

• CA 2021-0532, operator's personal breathing zone apparatus exceeded action levels due to a glovebox glove tear during blending operations on April 14, 2021

• CA 2021-0841, SNM spill inside UR facility due to an axial crack of a main extraction PVC column on June 5, 2021

• CA 2021-0870, material containing natural uranium (i.e., source material) powder self-ignited while being removed from work station 145 in the SFF area on June 16, 2021 Audits (IP Section 03.07)

The inspectors reviewed the internal audit listed below to determine whether it had been performed in accordance with 10 CFR 70.22(h)(1) and the license application.

• NCS-2021-040, NCS Violations and Observation Summary - 1st Quarter 2021 dated June 2, 2021 Radiation Work Permit (RWP) (IP Section 03.09)

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

• RWP 21-0031, "SFF Work Station 145 - Remove Fuel from the Top of Furnace," Rev. 0, conducted May 18, 2021

• RWP 21-0036, "Passivate Fuel Material in and around Work Station 145 Exhaust Line per Detailed Work Plan," Rev. 0, conducted June 18, 2021 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 7

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 processes listed below associated with SAR 15.38, "Process Development Lab (PDL),"

Rev. 33.

• precipitation, filtration, and rinsing

• waste handling

• 4-unit wall storage cabinet 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 (NFPA) 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 three fire areas listed below:

• Bays 13A, 14A, and 15A of the UR building 88135.17 - Permanent Plant Modifications The inspectors evaluated implementation of the configuration management system for facility changes or modifications to ensure that safety-related SSCs (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.

Facility Change/Modifications (IP Section 03.01)

The inspectors reviewed a facility change to the RTRT HFIR furnace excess temperature limit interlock IROFS circuitry, change package (CHG)-10568, to determine whether it was implemented in accordance with 10 CFR 70.72, Facility Changes and Change Process. Specifically, the inspectors reviewed the following:

• CHG-10568, "Upgrade RTR Heavy-Duty Overtemperature Controller (IROFS)," approved May 18, 2021

• N-517, "10 CFR 70.72, Change Evaluation Checklist (for NCS and IH&S),"

approved May 17, 2021

• SAR 15.23, "Fuel Plate and Element Fabrication Processes - RTRT Operations," Rev. 118

• technical basis for CHG-10568 8

• electrical schematic for the HFIR plate furnace (drawing 14ME4_1007, Rev. 0A)

Management Measures (IP Section 03.02)

The inspectors reviewed the following management measures to ensure that IROFS or other credited safety controls affected by the facility change identified above (i.e.,

CHG-10568) remained available and reliable to perform their function when needed to comply with the performance requirements of 10 CFR 70.61 or applicable conditions of the license:

• Configuration Management:

o verified the change package incorporated the applicable design requirements per NFPA 86, "Standards for Ovens and Furnaces" o verified the furnace excess temperature limit interlock set point had an established bases and that included instrument uncertainties o verified the change package identified the required post-maintenance test (PMT) necessary to verify the IROFS following change implementation

• Procedures:

o verified affected procedure (i.e., OP-1001944, "Furnace Testing for RTR General Shop Area," Rev. 9) was revised in accordance with the licensee's procedure control process

• PMT:

o observed and reviewed PMT results to confirm functional capability of the IROFS following change implementation

• Maintenance/Surveillance:

o verified the licensee established an adequate periodic calibration surveillance for a new excess temperature limit controller installed under the CHG 88135.19 - Post Maintenance Testing The inspectors evaluated PMT 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 four PMTs listed below. Tests were either observed directly or test results were reviewed.

• WO 20301627, "SFF WS-300 Secondary Coolant Loop Flow Switch Replacement," conducted on April 1, 2021

• WO 20302350, "Uranium Recovery Wet Scrubber Ethernet Switch Replacement," conducted on April 5, 2021

• WO 20301628, "SFF WS-145 Secondary Coolant Loop Flow Switch Replacement," conducted on April 8, 2021

• WO 20301670, "SFF WS-145 Secondary Coolant Loop 3-Way Valve Replacement," conducted on April 8, 2021 9

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 ISA.

Surveillance and Calibration Testing (IP Section 03.01)

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

• MPs 3425 and 118, UR Annular Organic and Waste Tanks Ultrasonic Measurement, conducted on April 1 and April 8, 2021, respectively

• MP-2251, RTR HFIR Plate Furnace Over-Temperature Interlock (IROFS)

Test, conducted on May 6, 2021 INSPECTION RESULTS WER (Closed) Concurrent report for OSHA reportable event (EN55220) 88135.02 WER 07000027/2021-001-00

Description:

During the early morning of April 28, 2021 an operator was transported and admitted to Lynchburg General Hospital by BWXTs emergency team due to the operator's fingers being pinched while positioning a component on a cart. BWXT made a report to the Occupational Safety and Health Administration (OSHA) at 12:30pm (EST) on April 28, 2021 due to a workplace injury requiring the hospitalization of an employee (i.e., OSHA reportable event under 29 CFR 1904.39(b)(2)). At approximately 9:00am (EST) on April 29, 2021 BWXT made a concurrent report (Event Number 55220) to the NRC's Operations Center in accordance with Paragraph (c) Concurrent Report of Appendix A to 10 CFR 70. The Written Event Report was reviewed. No violations of NRC requirements 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 operational safety inspection results to R. J. Freudenberger and other members of the licensee staff.

• On July 22, 2021, the inspectors presented the integrated inspection inspection results to R. J. Freudenberger and other members of the licensee staff.

10

DOCUMENTS REVIEWED Inspection Type Designation Description or Title Revision or Procedure Date 88020 Calculations RVY-2019-004- Evaluation of Hydrogen Generation in Recovery High-Level 01/11/2019 00 Dissolution Process Corrective Action 2020-0610, 2020-Documents 0655, 2020-0805, 2020-1208, 2020-1209, 2020-0488, 2021-0024 Corrective Action 2021-0566 Documents Resulting from Inspection Drawings 14AM9_1000 E Recovery Scrubber Piping & Instrumentation Diagram (P&ID) 1D 26815-01 Recovery Scrubber P&ID 10/04/2014 26815-08 Recovery Scrubber P&ID 01/09/2015 Engineering NCS-2001-084 NCS Technical Work Record 03/12/2001 Evaluations NCS-2007-186 Nuclear Safety Release for SER 06-047, Phase 2 08/14/2007 NCS-2017-007 NCS Technical Work Record 01/19/2017 NCS-2017-027 NCS Technical Work Record 02/08/2017 Miscellaneous AFB24-MFT Belimo Technical Data Sheet for Actuator E61-039 Uranium Recovery Duct Inspection Summary (Weekly) Completed 04/04/2021 E61-039 Uranium Recovery Duct Inspection Summary (6 Month) Completed 04/07/2021 E61-459 Uranium Recovery Personnel Training Record - Inspection 04/07/2020 and Cleaning of Recovery Ducts E61-459 Uranium Recovery Personnel Training Record - Scrubber 02/05/2021 Operation E61-99 Survey of Recovery Ducts (6 Month) Completed 04/07/2021 HS-2019-098 Second Quarter 2019 IH&S Audit Summary Report 08/26/2019 HS-2020-154 Third Quarter 2020 IH&S Audit Summary Report 11/24/2020 HS-2021-028 Fourth Quarter 2020 IH&S Audit Summary Report 03/02/2021 11

NCS-2004-251 Level 2 NCS Evaluation for SER 04-038, Phase 10/07/2004 NCS-2004-288 Nuclear Criticality Safety Release for SER 04-038, Phase 1 12/10/2014 NCS-2006-186 Level 3 Analysis: SER 06-047, Phase 2 01/16/2007 NCS-2007-066 Revised Requirements of SER 06-047, Phase 2 04/03/2007 NCS-2007-184 Additional Revised Requirements for SER 06-047, Phase 2 08/13/2007 NCS-2021-024 Justification for Continued Operations of SFF Workstation 140 03/10/2021 Following CA202100293 NCSE-03-02 NCS Quarterly Audit Commitment Follow-up, 1st Quarter 04/13/2021 2021 NMC-101520 2020 Annual Plant Ductwork Survey 10/15/2020 TP-REC-0001 Training Plan for Introduction to Recovery Rev. 1 TP-REC-0002 Training Plan for Advanced Recovery Operator Functions Rev. 0 TP-REC-0006 Training Plan for High-Level Dissolver Area Rev. 0 TP-REC-0012 Training Plan for Recovery Scrubber Rev. 0 TP-SFF-0001 Training Plan for Introduction Specialty Fuel Facility (SFF) Rev. 0 TP-SFF-0002 Training Plan for Advanced SFF Operator Functions Rev. 0 TP-SFF-0014 Training Plan for Operate WS 140 Rev. 0 TP-SFF-0015 Training Plan for FAS Calibrations Rev. 0 TP-SFF-0016 Training Plan for Operate 145 Rev. 0 TP-SFF-0017 Training Plan for Operate WS 300 Rev. 0 TP-SFF-0018 Training Plan for Upgrading Rev. 0 Procedures E41-134 Annual Ductwork Survey Rev. 16 HS-OP-004 Quarterly General Safety Audit Rev. 17 OP-0005021 Operating Procedure for 6-Inch Coating Furnace Scrubber Rev. 13 Operation and Maintenance OP-0061143 Uranium Recovery Scrubber Operation Rev. 35 OP-0061146 Deep Well Gamma Counter Operation Rev. 19 OP-0061150 Inspection and Cleaning of Recovery Ducts 33 OP-1001828 Operating Procedure for FAS Interlocks and Furnace Testing Rev. 38 OP-1015720 Operating Procedure for Coating in the Centorr Furnace for Rev. 43 TRISO OP-1016020 Operating Procedure for TRISO Coating Scrubber Operation Rev. 16 and Maintenance OP-1018265 Operating Procedure for SFF Supply Operations Rev. 21 OP-1018680 Recovery High-Level Dissolution Rev. 45 12

OP-1046323 Operating Procedure for TRISO FAS Detector Calibrations Rev. 2 QWI 14.1.1 Preventive/Corrective Action System 41 QWI 14.1.4 Reporting of Unusual Incidents Rev. 12 and Rev. 13 QWI 17.1.1 Environment, Safety, Health and Safeguards Audit Programs Rev. 12 Work Orders 20277555 (MP- HLD/LLD Airflow and HLD Airflow Loss Interlock 03/09/2020 2641) 20288149 (MP- SC AGR FIN. FURN. Interlock Test 1Y SFFO 09/09/2020 1301) 20288173 (MP- SC Test Valves SFSV-1 & SFV-2 1Y SFFO 09/09/2020 2342) 20289144 (MP- Recovery Scrubber Inspection 09/30/2020 636) 20290432 (MP- SC ZERO/SPAN GAS URPSM 6M 11/11/2020 2540) 20290436 (MP- SC ZERO/SPAN GAS CAL URPSM 6M 11/11/2020 2541) 20290439 (MP- SC DRAG ZERO/SPAN GAS URPSM 6M 11/11/2020 2542) 20290442 (MP- SC ZERO/SPAN GAS CAL URPSM 6M 11/11/2020 2544) 20290460 (MP- SC DRAG ZERO/SPAN GAS VAL LEL B URPSM 6M 11/11/2020 2550) 20292481 (MP- H2 Detector Testing, Calibration, and Interlock 11/03/2020 1465) 20296688 (MP- SC Wet Scrubber Encl. 6-MO SFFO 02/03/2021 1886) 20297863 (MP- HLD/LLD Airflow and HLD Airflow Loss Interlock 03/25/2021 2641) 20298576 (MP- Recovery Scrubber Inspection 03/25/2021 636) 20298600 (MP- Calibration of H2 Detectors 02/27/2021 1910) 20299265 (MP- Scrubber Fan Preventive Maintenance 03/03/2021 1805) 20299674 (MP- Inspection of Scrubber Fan and Sump 04/12/2021 13

4231) 20300046 (MP- Uranium Recovery Airflow Checks 03/25/2021 2411) 88135.02 Corrective Action 2020-0488 SFF WS-140 furnace missing material following run, incident 06/25/2021 Documents 04/09/2020 2020-1784 Autoclave vessel solution not sampled prior to dumping, 05/19/2021 incident 12/17/2020 2021-0224 FAS gas detector failed bump test, incident 02/17/2021 04/08/2021 2021-0407 Surface contamination noted on a treatment plant solids 06/18/2021 waste drum during offsite disposal facility receipt surveys, incident 03/22/2021 2021-0408 Operator used OOS I-matic instrument that failed the daily cal 06/14/2021 check, incident 03/24/2021 2021-0481 RTR encapsulated fuel cladding breached during sizing 06/14/2021 operation, incident 04/06/2021 2021-0532 Operator personal breathing zone apparatus exceeded action 06/14/2021 levels due to a rupture in one glovebox glove, incident 04/14/2021 2021-0648 HFIR furnace over-temperature test (management measure) 06/01/2021 could not be performed as written, incident 05/06/2021 Corrective Action 2021-0447 SFF workstation 145 coolant high-temperature interlock 06/23/2021 Documents controller (IROFS) readout drifting low Resulting from 2021-0503 SFF workstation 145 secondary coolant 3-way valve (IROFS) 06/01/2021 Inspection did not cycle as intended, incident date April 8, 2021 2021-0776 Question regarding excess temperature thermocouple 06/24/2021 certification versus application range CA2021-1033 IROFS not depicted on P&IDs 07/22/2021 COM-87513 IROFS not field tagged 07/22/2021 COM-91145 FSR-1 not updated 07/22/2021 Drawings 03-0966 Chamber and Hot One Assembly Rev. C 45-0066 Hot Zone Retrofit Kit Rev. B 58-0607 Gas System 08/25/2005 80-0922 Water System 08/25/2005 EOC_1004 Initial Emergency Assessment Flowchart Rev. 40 SFF-123 2 1/2" Furnace Coolant Rev. 2 Engineering HS-2011-103 Maximum Oxygen Concentrations for Common Combustible 08/15/2011 14

Evaluations Metals and Pyrophoric Materials NCS-2021-024 Justification of Continued Operations of SFF Workstation 140 03/10/2021 (CA2021-0293)

NCS-2021-033 NCS Safety Concern for Discharge of Retention Tank to 03/30/2021 Equalization Tank per CA2021-0408 NCS-2050-053 NCS Safety Concern for Fuel Outside of WS-140 Furnace 06/09/2020 Retort (CA2020-0408)

Miscellaneous NOG-L Shutdown 2021- Work Schedule 06/28/2021 Cleveland Electric Laboratories. Thermocouple Wire Data.

PDF File.

http://clevelandelectriclabs.com/literature/downloads/

A2LA Cert. No. Scope of Accreditation to ISO/IEC 17025:2017 & ANSI/NCSL 09/25/2019 1658.01 Z540-1-1994 - Cleveland Electric Laboratories COM-90106 Incorrectly Labeled IROFS in OP-1015277 E61-12 Gamma Well Counter Log (U-235 results for samples taken N/A on 06/05/2021 at 5:53 a.m.)

HPB-112/401 Engineering & Installation Guide - George Fischer Harvel LLC 07/22/2015 JA-WT-0024 Waste Operation - Out-of-Service Form Rev. 0 M0051/0793 OMEGA - 4200A Series RTD Temperature Controller -

Operator's Manual M42-054 Furnace Testing (SAP 1000888) 05/24/2021 N-50 Employee Review of Area Documents (Training Record for 06/22/2021 TP-WT-0001 and TP-WT-0009)

N-79 Evaluation of Unusual Incidents: Retention Tank Discharge to 04/01/21 Equalization Tank per CA2021-0408 N-79 Evaluation of Unusual Incident: RTR Fuel Breach in Clean 04/16/2021 Shop Area N-79 Evaluation of Unusual Incident: Leaking Column in Recovery 06/14/2021 N-79 Evaluation of Unusual Incident: Alpha Contamination Found 04/08/2021 on TP Solids Waste Drums Shipment N/A Recovery Operations Memo to UPRR Management, RE: 06/21/2021 Conduct of Operations Restart (Level 2) - Recovery Processing PVC Column N/A RP Air Flow Survey, Area: 14A Recovery Conversion Room Conducted 06/02/2021 N/A Glove Box Glove Survey: Recovery - 14A Conversion (Pages Conducted 15

1 and 2) 02/23/2021 N/A Glove Box Glove Survey: Recovery - 14A Conversion (Pages Conducted 1 and 2) 05/18/2021 N/A Alpha Fixed Air Sampling Week Report, Location: UPRR - Week Recovery Ending 04/18/2021 N/A Bittner, Jim, BWXT NOG-L, letter to U.S. Nuclear Regulatory 05/20/2021 Commission, 60-Day Written Report for Event Notification Number 55180 N/A Summer Shutdown Agenda 2021 - Industrial Engineering June 2021 07/02/2021 thru 07/11/2021 (ppt)

SAR 15.18 SFF Dry-End Processing SFF Operation Rev. 133 SAR 15.21 Low-Level Radioactive Waste Processes Rev. 79 SAR 15.21 Low-Level Radioactive Waste Processes Rev. 31 Appendix SAR 15.23 Fuel Plate and Element Fabrication Processes - RTRT Rev. 118 Operations SAR 15.28 Metallographic Laboratories Rev. 50 SRC2021-02 Safety Review Committee (SRC) Meeting Minutes for June 9, 06/09/2021 2021 TP-WT-0001 Training Plan: Introduction to Waste Treatment Rev. 2 TP-WT-0009 Training Plan: Waste Treatment Maintenance Rev. 2 WSRC-TR Peacock, H B. Sun , "Pyrophoricity of Uranium," United States March 1992 106 Procedures ADM-NOG-L- Conduct of Operations Rev. 3 0051 MP-4970 Inspection of SFF WS-140 Retort OP-0000015 Operating Procedure for HFIR Annealing Program Rev. 5 OP-0021201 (Classified Title) Rev. 51 OP-0061167 Spill and Leak Handling Emergency Procedure Rev. 36 OP-0061456 Glovebox and Hood Usage and Maintenance in Uranium Rev. 14 Recovery OP-0061556 Recovery Conversion Furnace Operations Rev. 22 OP-1001828 Operating Procedure for FAS Interlocks and Furnace Testing Rev. 37 OP-1001944 Furnace Testing for RTRT General Shop Area Rev. 8 OP-1015277 Fluid Bed Sintering in the Centorr Furnace for TRISO Rev. 25 16

QWI 14.1.01 Preventive/Corrective Action Rev. 40 QWI 14.1.01 - Preventive/Corrective Action System Severity Levels Rev. 17 Attachment 1 QWI 9.1.7 Preventive/Predictive Maintenance and Safety Related Rev. 12 Controls Testing Program RP-02-007 Enclosure Air Flow Measurements in Controlled Areas Rev. 11 Radiation Work 21-0019 Visual Inspection and Cleaning of Drums of TP Solids Rev. 0 Permits (RWPs) Located in Field Area of Waste Treatment Facility Work Orders 20272536 SFF WS-140 Retort Inspection 04/05/2020 20285627 SFF WS-140 Retort Inspection 06/18/2020 20296557 Replacement of Special Fuel Facility WS-145 Cooling Water 01/15/2021 Temperature Controller IROFS 20302888 RTRT HFIR Plate Furnace Over-Temperature Interlock Test - 05/24/2021 1Y (MP-2251) 220304227 RTRT HFIR Furnace Controller Issue 05/13/2021 88135.04 Corrective Action 2016-1550 Chemical solution bottle in PDL missing identifying 05/11/2021 Documents markings/labels, incident 11/17/2016 2017-1071 Incorrect management measure OP listed in SAR 15.39, 05/11/2021 incident 08/17/2017 2018-1481 NCS engineer inspection preparation expectations, incident 05/11/2021 10/25/2018 2019-0406 Solution not pre-filtered prior to disposal via hot waste drain, 05/11/2021 incident 03/25/2021 2019-0522 Instructions needed for disposing modified shop vacuum 05/11/2021 waste, incident 03/18/2019 Corrective Action 2021-0978 Operations no longer performed still described in SAR 15.39 07/12/0221 Documents (PDL)

Resulting from Inspection Drawings CRF-661 Bay 14A Mezzanine Annex SNM Wall Storage Cabinets Rev. 0 UPRR-10050 Dissolver-Waste System P&ID Rev. 3 Engineering CHG-3892 Revision to PDL Maintenance Plan 1623 12/14/2017 Changes CHG-4214 Modify PDL Precipitation Hood Window and Frame and Add 07/30/2018 Hoist for Lifting and Lowering CHG-5430 Deactivate PDL Tube Furnaces 1-3 and PDL Reagent 10/11/2018 Columns 17

CHG-5566 DU, NU, and Low-Enriched Liquid Waste Handling in PDL 11/29/2018 and SFF CHG-5857 Revise PDL Precipitation OP 02/07/2019 CHG-6299 New NCS Posting for PDL Lab Sink 09/12/2019 CHG-9975 Resume PDL Precipitation and WS-130 Oxidation 03/08/2021 Miscellaneous RP Air Flow Survey, SFF Area: PDL Dissolver Prep, PDL Conducted Annex Glovebox, and PDL Vent Hood 06/02/2021 SAR 15.39 Process Development Lab (PDL) Rev. 33 SAR 15.39 Process Development Lab (PDL) Rev. 10 Appendix Procedures MP-1623 PDL Lab Equipment/Systems Inspection and Tests OP-1001827 Waste/Scrap Handling and Disposal - SFF Area (U) Rev. 30 OP-1046138 Process Development Lab - Waste Columns (U) Rev. 3 Work Orders 20292846 Inspect Fuel Reclamation System - 6 Month (safety class) 10/22/2020 20300031 Inspect Fuel Reclamation System (safety class) 05/06/2021 88135.05 Engineering HS-2021-016 MTS Fire Extinguisher Removal/Replacement 02/08/2021 Evaluations Fire Plans Section 13 Area: Bays 12A, 13A, 14, and 15A (map sections reviewed 01/15/2021 13, 13A, 13B, 13C, 13M)

Miscellaneous FSR-01 Facility Siting Review 1 - Locations of Focus: Bays 12A, 13A, Rev. 05 14A, 15A 88135.17 Corrective Action 2021-0648 MP-2251 over-temperature test (management measure) could 06/01/2021 Documents not be performed as written, incident 05/06/2021 Drawings 14ME4_1007 Lindburg HFIR Furnace Electrical Schematic, Sheets 1 thru 5 Rev. 0A Engineering CHG-10628 Update OP-1001944 June 30, Changes 2021 Miscellaneous Calibration RTRT HFIR Anneal Furnace Temperature Controller (ACE- Completed Certificate 00945) 05/10/2021 429253-2 M42-054 Furnace Testing (SAP 1000888) Completed 05/24/2021 N-517 10 CFR 70.72 Change Evaluation Checklist for CHG-10568 05/17/2021 (IH&S/NCS)

NFPA 86 Standard for Ovens and Furnaces 2019 SAR 15.23 Fuel Plate and Element Fabrication Processes - RTRT Rev. 118 Operations 18

Procedures OP-0000015 HFIR Annealing Program Rev. 5 OP-1001944 Furnace Testing for RTRT General Shop Area Rev. 9 Work Orders 20302888 RTRT HFIR Plate Furnace Over-Temperature Interlock Test - 05/24/2021 1Y (MP-2251) 88135.19 Corrective Action 2021-0085 Uranium recovery wet scrubber loss of primary fan ventilation 06/28/2021 Documents due to recirculation pump malfunction, incident 01/16/2021 2021-0503 SFF WS-145 IROFS 3-way valve is sticking, incident 06/12/2021 04/08/2021 Corrective Action 2021-0815 Maintenance work request did not Identify affected 06/10/2021 Documents component as an IROFS Resulting from Inspection Drawings 8173-E-1020 TRISO Finishing Furnace System Schematics, Sheet 6 of 52 Rev. 0 UPRR-10061 Work Station 300 Cooling System P&ID Rev. 4 UPRR-10068 Work Station 145 P&ID Rev. 4 UPRR-30138 Recovery Scrubber Makeup and Water/Drain Rev. 4 UPRR-30139 Recovery Scrubber Recirculation Line and Sight Glass Rev. 1 Miscellaneous MS-01-146 Ball Valves, General Purpose, and Special Application, Rev. Y Swagelok Company, November 2019 SAR 15.14 Scrubber Ventilation and Vacuum System in Uranium Rev. 75 Recovery SAR 15.18 SFF Dry-End Processing Operation Rev. 133 SAR 15.5 High-Level Dissolution Process in Uranium Recovery Rev. 142 Procedures OP-1001828 FAS Interlocks and Furnace Testing (Section 9.12) Rev. 38 OP-1015277 Fluid Bed Sintering in the Centorr Furnace for TRISO Rev. 25 QWI 9.1.7 Preventive/Predictive Maintenance and Safety-Related Rev. 12 Controls Testing Program Work Orders 20302350 Uranium Recovery Wet Scrubber Ethernet Switch Conducted Replacement 04/05/2021 88135.22 Corrective Action 2021-0648 MP-2251 over-temperature test (management measure) could 06/01/2021 Documents not be performed as written, incident 05/06/2021 Drawings EBP-50004D Raffinate Tank Circular Design 72" O.D. 1 1/2" Annulus Rev. 1 (Sheets 1 to 3)

UPRR-30073 Annular Organic Tank P&ID Rev. 1 UPRR-30116 Annular Waste Tank P&ID Rev. 3 Miscellaneous E61-597 Ultrasonic Inspection and Measurement Data For Annular 19

Tanks and Cylindrical Columns, completed in 2019 and 2021 for Annular Organic and Raffinate Waste Tanks #1 and #2 Inner/Outer/Annulus Thickness Measurements in Recovery Area M42-054 Furnace Testing (SAP 1000888) Completed 05/24/2021 SAR 15.12 Liquid and Solid Waste Handling Processes in Uranium Rev. 83 Recovery SAR 15.23 Fuel Plate and Element Fabrication Processes - RTRT Rev. 118 Operations Procedures OP-0000015 HFIR Annealing Program Rev. 5 OP-1001944 Furnace Testing for RTRT General Shop Area Rev. 8 OP-1004612 Ultrasonic Inspection Procedure for Annular Tanks and Rev. 8 Cylindrical Columns Work Orders 20222986 RTRT HFIR Plate Furnace Over-Temperature Interlock Test - 05/31/2017 1Y (MP-2251) 20241407 RTRT HFIR Plate Furnace Over-Temperature Interlock Test - 05/28/2018 1Y (MP-2251) 20262133 RTRT HFIR Plate Furnace Over-Temperature Interlock Test - 05/24/2019 1Y (MP-2251) 20282300 RTRT HFIR Plate Furnace Over-Temperature Interlock Test - 05/07/2020 1Y (MP-2251) 20297424 UR Waste Tanks Annulus/Wall Thickness Ultrasonic 04/12/2021 Measurement (MP-118) 20297447 Training and Notification in Preparation of Waste/Organic 03/11/2021 Tank Ultrasonic Measurement (MP-3133) 20297687 UR Organic Tank Annulus/Wall Thickness Ultrasonic 04/01/2021 Measurement (MP-3425) 20302888 RTRT HFIR Plate Furnace Over-Temperature Interlock Test - 05/24/2021 1Y (MP-2251) 20