ML21293A113

Nuclear Fuel Services, Inc., Core Inspection Report 07000143/2021003

ML21293A113
Person / Time
Site:	Erwin
Issue date:	10/20/2021
From:	Chutima Taylor NRC/RGN-II/DFFI
To:	Burch J Nuclear Fuel Services
References
IR 2021003
Download: ML21293A113 (18)

Text

October 20, 2021 Mr. Joel Burch President (Acting)

Nuclear Fuel Services, Inc.

P.O. Box 337, MS 123 Erwin, TN 37650-0337

SUBJECT:

NUCLEAR FUEL SERVICES, INC. - CORE INSPECTION REPORT 07000143/2021003

Dear Mr. Burch:

On September 30, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at the Nuclear Fuel Services (NFS) facility. On October 13, 2021, the NRC 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.

The enclosed report documents one Severity Level IV violation of NRC requirements. This violation is being treated as a Non-Cited Violation (NCV), consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violation or severity of the NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001, with copies to: (1) the Regional Administrator, Region II; (2) the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and (3) the NRC Resident Inspector at the NFS facility.

J. Burch 2 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/

Cynthia D. Taylor, Chief Projects Branch 1 Division of Fuel Facility Inspection Docket No. 07000143 License No. SNM-124

Enclosure:

As stated cc w/ encl: Distribution via LISTSERV

ML21293A113 SUNSI Review Non-Sensitive Publicly Available Sensitive Non-Publicly Available OFFICE RII/DFFI RII/DFFI RII/DFFI RII/DFFI NAME L. Harris J. Rivera-Ortiz N. Pitoniak C. Taylor DATE 10/13/2021 10/13/2021 10/13/2021 10/20/2021 U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number: 07000143 License Number: SNM-124 Report Number: 07000143/2021003 Enterprise Identifier: I-2021-003-0115 Licensee: Nuclear Fuel Services, Inc.

Facility: Nuclear Fuel Services, Inc.

Location: Erwin, TN Inspection Dates: July 01, 2021 to September 30, 2021 Inspectors: L. Harris, Senior Resident Inspector N. Pitoniak, Sr. Fuel Facility Project Inspector J. Rivera Ortiz, Sr. Fuel Facility Project Inspector Approved By: Cynthia D. Taylor, 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 a core inspection at Nuclear Fuel Services, 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 Contaminated Items Discovered at Warehouse (EN 55161/55431)

Significance Report Section Severity Level IV 88135.02 NCV 07000143/2021003-01 Closed The inspectors' review of EN 55161/55431, "Contaminated Items Discovered at Warehouse,"

resulted in a licensee-identified, Severity Level-IV, non-cited violation (NCV) of 10 CFR 71.5, "Transportation of licensed material," and Condition S-1 of the license.

Additional Tracking Items None.

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PLANT STATUS The following facility process areas were operating during the inspection period: Naval Fuel Manufacturing Facility (FMF) and the Blended Low Enriched Uranium (BLEU) Preparation Facility (BPF), which includes the U-Oxide, Solvent Extraction and the down-blending lines.

Normal support services and departments were operational during the inspection period.

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, Part 70 (10 CFR 70), 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 and fire safety based on 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:

• Area 200 Accident Sequences: 4.1.1-05, 4.1.2-01, 4.1.4-02.g, 4.1.5-03.b, 4.1.8-01.a, and 4.1.13-02.d

• Area 300 Accident Sequences: 4.1.3.4, 4.1.4.4.1.b, 4.1.5.4.3, 4.1.13.4, FRE-01a, FRE-06a, and FRE-B02 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 3

was performed to verify that the controls or IROFS were available and reliable to perform their intended safety functions and that design basis assumptions were reflected in the actual conditions in the field. The specific safety controls selected for review are listed below:

• Area 200 IROFS: FA1-3, FA1-13, FA1-4, FMF-18, FMF-19, FA1-31, FMF-9, FA1-30, FA1-6, FA1-12, FA1-8, FA1-11, FA1-16, FA1-21, FA1-22, FA1-5, and FA1-10

• Area 300 IROFS: 300-4, 300-5, 300-6, 300-7, 300-10A, 300-9, 300-11, 300-12, 300-13, 300-4, 300-5, FIRE-2 and FIRE 1 Implementation of Safety Controls (IP Section 02.03)

For the selected safety controls listed above, the inspectors reviewed management measures to verify implementation was 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 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:

• reviewed a sample of the implementing procedures for IROFS 300-4, 300-5, 300-10A, 300-11, and 300-12

• reviewed operating procedures for Areas 200 and 300 to verify that selected IROFS were implemented in the procedure

• conducted walk-downs and observed operations in Areas 200 and 300 and interviewed operators to verify that selected IROFS were present and performed as intended

• reviewed a sample of Area 300 runsheets to verify IROFS implementation

• reviewed calculations for Area 200 to identify assumptions and boundary conditions and verify consistency with operating conditions

• reviewed ISA Risk Assessment for Areas 200 and 300 to identify assumptions and boundary conditions and verify consistency with operating condition 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 a sample of surveillance test records for selected IROFS in Areas 200 and 300

• interviewed licensee staff in charge of training and reviewed operator training material for Areas 200 and 300

• reviewed training records for three operators and two supervisors assigned to Area 200

• reviewed training records for three operators and one supervisor assigned to Area 300 4

• interviewed licensee staff to confirm whether recent plant modifications associated with Areas 200 and 300 had occurred to verify that configuration management measures were consistent with the license requirements

• reviewed a sample of problems entered into the Corrective Action Program (CAP) related to IROFS issues in Areas 200 and 300 to verify that corrective action management measures were consistent with the license requirements

• reviewed the schedule of audits and self-assessments in the Operations Area to verify compliance with the license requirements

• conducted walk-downs of Areas 200 and 300 to determine whether housekeeping conditions had adverse effects on process safety or IROFS safety functions 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 licensed activities were conducted safely and in compliance with the license and 10 CFR 70, Domestic Licensing of Special Nuclear Material.

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 and ensure inspection resources were appropriately focused on those activities with the higher safety significance.

• Meetings Attended: Inventory planning, Plan of the Day, Problem Identification and Resolution, Safety and Safeguards Review Council, Corrective Action Review Board 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 5

problems in accordance with 10 CFR 70.62(a)(3) and applicable license requirements.

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 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).

• Event Notifications (ENs) 55161 and 55431, "Contaminated Items Discovered at Warehouse." This event was reported on March 30th, 2021 as EN 55161 and involved contaminated components inside legacy equipment stored at the Industrial Park Facility (IPF). At the time of discovery, this event was thought to involve Category III quantities of SNM (Low Strategic Significance) based on conservative nondestructive assay and was reported under the provisions of 10 CFR 73 (security-related). On April 26, 2021, the licensee retracted the security-related aspect of the event based on further evaluation of the amount of material involved and better technical understanding of the issue. However, the licensee still considered the issue as a reportable event under 10 CFR 20.2203(a)(3)(ii).

On April 27th, 2021, the licensee submitted a written follow-up report to the NRC for EN 55161 describing the known circumstances of the event and corrective actions (ADAMS ML21146A155). This follow-up report contains "official use only" information and is not publicly available. However, on August 25, 2021, the licensee submitted a new Event Notification (EN 55431) to capture the transportation and radiation safety aspects of the event in a publicly available notification. Additionally, on September 17, 2021, the licensee resubmitted the follow-up report for the event redacting the "official use only" information (ADAMS ML21272A257). The NRC evaluated this issue in accordance with Management Directive 8.3, "NRC Incident Investigation Program" and determined that routine follow-up inspection was the appropriate level of response commensurate with the safety significance of the event and licensee's immediate corrective actions. The NRC resident inspector as well as NRC regional staff conducted follow-up activities for this event to assess the licensee's response and corrective actions.

The inspectors identified a violation associated with this event; see the "Inspection Results" section of this inspection report for details.

Audits (IP Section 03.07)

The inspectors reviewed the internal and/or external audits listed below to determine whether they have been performed in accordance with 10 CFR 70.22(h)(1) and the license application.

• Internal Audits Completed in the 2nd Quarter: Health Physics, SNM 125-4 Quarterly Safety Audits, Environmental Safety, ALARA Performance Report, Industrial Safety, Nuclear Criticality Safety, and Outside Agency Violations 6

Procedures (IP Section 03.08)

The inspectors reviewed and observed implementation of the procedures listed below to ensure that safety-significant procedures were developed and/or maintained in accordance with Chapter 11 "Management Measures", of the license application, the Change Management System, and implementing procedures:

• NFS-HS-E-02, Rev. 049, Emergency Criticality Evacuation (procedure revision)

• NFS-HS-E-04, Rev. 041, Fire Reporting and Response (procedure revision)

• NFS-HS-E-15, Rev. 020, Emergency Medical Response (procedure revision)

Radiation Work Permit (RWP) (IP Section 03.09)

The inspectors reviewed and observed the safety work permits (SWPs) listed below to determine whether the SWPs contained the information required by Chapter 4, "Radiation Safety" of the license application, the Radiation Protection Manual; and implementing procedures:

• SWP 21-29-019 333 S-X (repair)

• SWP 17936 300 CMPLX (repair)

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

The inspectors observed the licensees performance during the Emergency Preparedness training evolution listed below to determine they were being implemented in accordance with 10 CFR 70.22(I)(3):

• On September 28, 2021, the inspectors observed an emergency training drill.

The drill simulated a significant fire in Building 105. The emergency operations center was activated and the scenario involved an injured victim, simulated offsite transport, event classification, and notification of offsite organizations.

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 systems and sub-systems for the processes listed below associated with Building 333.

• BPF U-Oxide System including reviews of selected IROFS:

N333XDRAINH3C07 and 09, BUM-002, N333XWOGVNT3C01 and D01, 7

N333VALVEBA3A25 and B25, N333XSCREEN3A01 and B01, and N333VLALRM3F04. Additionally, selected safety required equipment tests were reviewed.

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 one fire area and one annual system performance test listed below:

• Building 110, including associated hydrants and annual sprinkler inspection

• Annual CO2 system performance test 88135.17 - Permanent Plant Modifications The inspectors evaluated implementation of the configuration management system (CMS) 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.

Facility Change/Modifications (IP Section 03.01)

The inspectors reviewed modifications to the Area 800 blowback system to determine whether they were implemented in accordance with 10 CFR 70.72, Facility changes and change process. Specifically, the inspectors reviewed the following:

• Equipment change packages 20213038, 20213067, and 20212123 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 controls following maintenance.

Post-Maintenance Testing (IP Section 03.01)

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

• N303XIGNTBSS671

• N333XDRAINH2I07 8

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

• N333VALVHV5A01A

• N306FILTERA811 INSPECTION RESULTS Contaminated Items Discovered at Warehouse (EN 55161/55431)

Severity Report Section Severity Level IV 88135.02 NCV 07000143/2021003-01 Closed The inspectors' review of EN 55161/55431, "Contaminated Items Discovered at Warehouse,"

resulted in a licensee-identified, Severity Level-IV, non-cited violation (NCV) of 10 CFR 71.5, "Transportation of licensed material," and Condition S-1 of the license.

Description:

On March 30, 2021, the licensee identified contamination on the internal surfaces of a retired process enclosure and miscellaneous components resting inside the enclosure. The enclosure was located in the IPF, a licensee-controlled warehouse near the NFS site. The enclosure had been stored at the IPF since February 2009. The contamination was found while the enclosure was being inspected for disposal in accordance with licensee procedure NFS-GH-63, "Unrestricted Equipment/Item Release." There were no contamination levels of concern on the external surfaces of the enclosure or the surrounding areas; however there was contamination exceeding regulatory limits on the surface of miscellaneous components resting inside the enclosure. Specifically, removable contamination levels on the surfaces of the components exceeded the limits for shipping packages established in the Department of Transportation (DOT) regulations incorporated by reference in 10 CFR 71.5. The highest point of alpha-emitting removable contamination measured by the licensee was 112.4 disintegrations per minute per square centimeter (dpm/cm2), which exceeded the 49 CFR 173.443 limit of 24 dpm/cm2.

At the time the contamination was discovered, the enclosure was wrapped and did not have indications of tampering, but neither the enclosure nor the surrounding area was properly marked or labeled as required by the license or NRC regulations. Furthermore, when the enclosure was moved from the NFS site to the IPF warehouse in 2009, the licensee did not use the controls identified in 10 CFR 71.5 to transport the item on public highways. While NFS's license allows storage of SNM in sealed containers at the IPF, the as-found configuration of the enclosure did not constitute a sealed container or a shipment package appropriate for transportation of contaminated components.

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On April 7, 2021, the licensee started to remove the contaminated components from the enclosure for a more accurate accountability of the material. The licensee determined that the total amount of SNM involved was approximately 4.32 grams and was below the threshold for Category III quantities of uranium-235 (U-235). On April 9, 2021, the licensee returned all the material to the main NFS site in sealed containers approved for public road transportation via an authorized shipper. The licensee also decontaminated the empty process enclosure to the extent practicable and shipped it directly from the IPF for low level waste disposal.

Corrective Actions: The licensee captured this issue in the CAP and took prompt actions to properly handle the material and report the issue to the NRC. Corrective actions included radiation surveys to characterize the contamination and amount of SNM in the enclosure, proper marking and posting of the enclosure and general area, recovery and shipment of the material to the NFS site using sealed packages approved for transportation on public highways, decontamination of the empty enclosure for disposal, and walkdowns of the IPF and other plant areas to identify the extent of condition. The licensee also established an investigation team to determine the root cause of the event and develop corrective actions to prevent recurrence. The cause of the event was determined to be inadequate radiation surveys and inspection of the enclosure prior to unrestricted release from the site. Proposed corrective actions to prevent recurrence included revision of equipment survey release guidance and evaluation criteria contained in site procedures.

Corrective Action

References:

PIRCS 83261 Analysis: The inspectors determined that the failure to properly survey and inspect the process enclosure for unrestricted release and transportation on public highways was a violation of 10 CFR 71.5 and Condition S-1 of the license. The violation was determined to be of more-than-minor significance in accordance with the guidance in NRC IMC-0616, "Fuel Cycle Safety and Safeguards Inspection Reports" and by comparison with the violation examples in the NRC Enforcement Policy. Specifically, the violation aligned with Example 6.8.d.2 of the NRC Enforcement Policy because the surface contamination inside the enclosure was in excess of, but was not more than five times, the NRC limit established in 10 CFR 71.5 (49 CFR 173.443). Based on the information gathered through inspection, the NRC determined there were no indications of adverse safety consequences to plant workers, the public, or the environment as a result of this event. The NRC also determined that the violation was not repetitive as a result of inadequate corrective actions.

Enforcement:

Severity: This violation was determined to be Severity Level IV consistent with Example 6.8.d.2 of the NRC Enforcement Policy.

Violation: 10 CFR 71.5(a) states, in part, Each licensee who transports licensed material outside the site of usage, where transport is on public highways, shall comply with the applicable requirements of the DOT regulations in 49 CFR parts 107, 171 through 180, and 390 through 397, appropriate to the mode of transport, in the areas of packaging, marking and labeling, and placarding the material."

Special Nuclear Material License SNM-124, Condition S-1, states, in part, that the licensee shall conduct activities in accordance with the statements, representations, and conditions in the license application. Chapter 4 of the NFS License Application, Section 4.7.11.7, states that surface contamination surveys are conducted for contamination prior to release of potentially contaminated packages, equipment, vehicles, scrap, or waste from radiologically controlled areas to uncontrolled areas or for unrestricted release. Additionally, Chapter 1, 10

Section 1.1.2, states that the IPF warehouse may be used for nuclear materials storage in sealed containers while awaiting processing, treatment, or shipment off-site.

Contrary to the above, in February 2009, the licensee failed to properly survey, package, mark and label, and placard licensed material contained in a process enclosure before transporting the material outside the site on public highways. Additionally, from February 2009 to April 2021, the licensee failed to store licensed material at the IPF warehouse in a sealed package in accordance with the license application. This violation is identified as NCV 07000143/2021003-01, "Contaminated Items Discovered at Warehouse" for administrative tracking purposes.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

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

• On August 12, 2021, the inspectors presented the operational safety (IP 88020) inspection results to Mr. Mike Tesar, Program Management Director, and other members of the licensee staff.

• On October 13, 2021, the inspectors presented the third quarter core inspection results to Joel Burch and other members of the licensee staff.

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DOCUMENTS REVIEWED Inspection Type Designation Description or Title Revision or Procedure Date 88020 Calculations 21X-19-0026 IROFS and Safety-Related Equipment - Areas 100 and 200 Rev. 8 88020 Calculations 21X-21-0003 Integrated Safety Analysis Summary - Areas 100 to 900 Rev. 17 88020 Calculations 54T-97-046 Criticality Safety Analysis for the High Efficiency Particulate 12/1997 Airborne Filters at NFS 88020 Calculations 54X-13-0010 Area 100/200 Rev. 6 88020 Calculations SEB-19-003 Setpoint Analysis (Area 200) 08/21/2019 88020 Corrective Action PIRCS 80281 Area 300 08/17/2020 Documents 88020 Corrective Action PIRCS 80479 Area 300 09/10/2020 Documents 88020 Corrective Action PIRCS 80551 Area 200 09/19/2020 Documents 88020 Corrective Action PIRCS 80618 Area 300 09/29/2020 Documents 88020 Corrective Action PIRCS 80635 Area 300 9/29/2020 Documents 88020 Corrective Action PIRCS 80636 Area 300 09/29/2020 Documents 88020 Corrective Action PIRCS 84444 Area 200 08/02/2021 Documents 88020 Corrective Action PIRCS 84534 Chiller Labeling 08/12/2021 Documents Resulting from Inspection 88020 Corrective Action PIRCS 84534 Area 200/300 10/04/2021 Documents Resulting from Inspection 88020 Corrective Action PIRCS 84535 ISA Summary - Area 200 08/11/2021 Documents Resulting from Inspection 12

Inspection Type Designation Description or Title Revision or Procedure Date 88020 Corrective Action PIRCS 84550 Area 200/300 08/12/2021 Documents Resulting from Inspection 88020 Drawings 302-A0089-D Floor Contours Building 302 06/19/2001 88020 Drawings 302-F0112-D Area 200 - PI&D Sheet 1 07/20/2020 88020 Drawings 302-F0113-D Area 200 - PI&D Sheet 2 06/24/2021 88020 Drawings 302-F0114-D Area 300 P&ID - Sheet 1 07/30/2020 88020 Drawings 302-F0115-D Area 300 P&ID - Sheet 2 08/04/2020 88020 Drawings 302-F0116-D Area 400 P&ID - Sheet 1 07/30/2020 88020 Engineering ECR 20201136 Building 303 CO2 Changes 88020 Miscellaneous 27X-15-0004 Lesson Plan - Test A (1 Operator) 10/06/2017 88020 Miscellaneous 27X-15-0004 Lesson Plan - Area 200 Checklist (1 Operator) 10/06/2017 88020 Miscellaneous 27X-20-0009 Lesson Plan - Test A (1 Operator) 05/12/2021 88020 Miscellaneous 27X-20-0009 Lesson Plan - Area 200 Checklist (1 Operator) 05/13/2021 88020 Miscellaneous 27X-21-0003 Lesson Plan - Test A (1 Operator) 06/16/2021 88020 Miscellaneous 27X-21-0003 Lesson Plan - Area 200 Checklist (1 Operator) 06/18/2021 88020 Miscellaneous 27X-21-0003 Lesson Plan - Area 200 Checklist (2 Supervisors) 07/02/2021 88020 Miscellaneous 27X-21-0003 Lesson Plan - Test A (2 Supervisors) 07/02/2021 88020 Miscellaneous 27X-21-0003 NFS Training Department Lesson Plan - Area 200 Operator 05/18/2021 Training 88020 Miscellaneous FM-GH-62-01-01 NFS Monthly Combustible Control Inspection Form (various) 88020 Miscellaneous FM-TRN-039 3Y Re-qualification Checklist for Operators (1 Operator) 12/30/2020 88020 Miscellaneous N302COLUMNB201 Safety Related Test - IROFS FA1-005 (Area 200) 06/21/2021 88020 Miscellaneous N302PSHLPN2NI01 Safety Related Test - IROFS FMF-18/19 (Area 200) 07/10/2021 88020 Miscellaneous N302XCOLUMN0101 Safety Related Test - IROFS FA1-005 (Area 200) 12/19/2020 88020 Miscellaneous N302XCOLUMNA201 Safety Related Test - IROFS FA1-005 (Area 200) 06/21/2021 88020 Miscellaneous N302XDRAINHA101 Safety Related Test - IROFS FA1-30 (Area 200) 6/22/2019 88020 Miscellaneous N302XDRAINHA201 Safety Related Test - IROFS FA1-030 (Area 200) 08/2/2021 88020 Miscellaneous N302XDRAINHB101 Safety-Related Test - IROFS FA1-6 (Area 200) 06/23/2019 88020 Miscellaneous N302XDRAINHB201 Safety Related Test - IROFS FA1-006 (Area 200) 08/02/2021 13

Inspection Type Designation Description or Title Revision or Procedure Date 88020 Miscellaneous N302XMVXXXXA301 Safety Related Test - IROFS 300-12 (Area 300) 07/19/2021 88020 Miscellaneous N302XMVXXXXA302 Safety Related Test - IROFS 300-12 (Area 300) 07/19/2021 88020 Miscellaneous N302XMVXXXXB301 Safety Related Test - IROFS 300-12 (Area 300) 07/14/2021 88020 Miscellaneous N302XMVXXXXB302 Safety Related Test - IROFS 300-12 (Area 300) 07/14/2021 88020 Miscellaneous N302XXXXLSHNIA1 Safety Related Test - Building 302 07/10/2021 88020 Miscellaneous N302XXXXLSHNIA2 Safety Related Test - Building 302 7/10/2021 88020 Miscellaneous N302XXXXLSHNIA3 Safety Related Test - Building 302 7/10/2021 88020 Miscellaneous N302XXXXPDAA316 Safety Related Test - IROFS 300-10A (Area 300) 03/21/2021 88020 Miscellaneous N302XXXXPDAA318 Safety Related Test - IROFS 300-10A (Area 300) 03/21/2021 88020 Miscellaneous N302XXXXPDAB316 Safety Related Test - IROFS 300-10A (Area 300) 02/22/2021 88020 Miscellaneous N302XXXXPDAB318 Safety Related Test - IROFS 300-10A (Area 300) 07/19/2021 88020 Miscellaneous OS-302-200 Supervisor Classroom-Area 200 OJT Training Completion Records (2 Supervisors) 88020 Miscellaneous OT-302-200 Operator Classroom - Area 200 OJT Training Completion Records (3 Operators) 88020 Miscellaneous PB-2016-0305 Flanders - Nuclear Grade HEPA Filters 88020 Procedures 21T-20-0109 SNM-124 License Flowdown - Chapter 11C, Training and Rev. 2 Qualification 88020 Procedures NFS-GH-56 Management Measures Identification and Implementation 05/15/2020 for IROFS 88020 Procedures NFS-GH-62 Control of Combustibles Rev. 14 88020 Procedures NFS-M-48 Quality Assurance Program Rev. 7 88020 Procedures NFS-TN-008 NFS Training Procedure Rev. 16 88020 Procedures SOP 401-02-302 Area 200 03/01/2021 88020 Self-Assessments 56T-19-0097 2019 Quality Assurance/Quality Control Consolidated Rev. 2 Audit/Assessment Schedule 88020 Self-Assessments 56T-20-0076 2020 Quality Assurance/Quality Control Consolidated Rev. 3 Audit/Assessment Schedule 88020 Self-Assessments 56T-21-0117 2021 Quality Assurance/Quality Control Consolidated Rev. 2 Audit/Assessment Schedule 88020 Work Orders WR 293761 Building 303 CO2 work request 88135.02 Miscellaneous 21 G-21-0129 30-Day Report, EN-55431 No Security Related Information 09/17/2021 88135.02 Self-Assessments Health Physics Audits/Inspections 2nd Quarter 2021 14

Inspection Type Designation Description or Title Revision or Procedure Date 88135.02 Self-Assessments SNM-124 Quarterly Safety Audits , ISA and Fire Protection Programs, Second quarter 2021 88135.02 Self-Assessments Second Quarter 2021 Environmental Safety inspections/Audits 88135.02 Self-Assessments Second Quarter 2021 ALARA Performance Report for Environmental - Radiological 88135.02 Self-Assessments Industrial safety 2021 Q2 88135.02 Self-Assessments NCS Audits and Inspections, 2nd Quarter 2021 88135.02 Self-Assessments Outside Agency Violations with Safety Significance 2nd Quarter 2021 88135.04 Operability N333LVLALRM3F04 Safety Related Equipment test 02/26/2021 Evaluations 88135.04 Operability N333NOXDET3X18 Safety Related Equipment Test 07/16/2021 Evaluations 88135.04 Operability N333WOGVNT3D06 Safety Related Equipment Test 05/20/2021 Evaluations 88135.04 Operability N333XDRAINH3C09 Safety Related Equipment Test 03/08/2021 Evaluations 88135.04 Operability N333XSCREEN3B01 Safety Related Equipment Test 07/13/2021 Evaluations 88135.05 Fire Plans 2IT-19-0498 Fire Hazard Analysis, Building 110 05/07/2019 88135.05 Miscellaneous Inspection number Annual Building 110 Sprinkler Inspection 04/12/2021 376 88135.05 Miscellaneous N302XXCO2SYSTEM Annual CO2 fire system test 07/09/2021 88135.17 Engineering ECR20213038, Area 800 Blowback Modifications Changes 20212123, 20213067 15