ML22027A552

Nuclear Fuel Services - Core Inspection Report IR 07000143/2021004 Final

ML22027A552
Person / Time
Site:	Erwin
Issue date:	01/28/2022
From:	Robert Williams NRC/RGN-II/DFFI/FFB1
To:	Dailey R Nuclear Fuel Services
Rivera Ortiz J
References
IR 2021004
Download: ML22027A552 (33)

Text

January 27, 2022 Mr. Ronald Dailey President NUCLEAR FUEL SERVICES, INC.

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

SUBJECT:

NUCLEAR FUEL SERVICES - CORE INSPECTION REPORT 07000143/2021004

Dear Mr. Dailey:

On December 31, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Nuclear Fuel Services. On January 19, 2022, 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, Robert E. Williams, Jr., 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 Signed by Williams, Robert on 01/27/22

ML22027A552

SUNSI Non-Sensitive Publicly Available Review Sensitive Non-Publicly Available

OFFICE RII/DFFI RII/DFFI RII/DFFI RII/DFFI RII/DFFI RII/DFFI RII/DFFI RII/DFFI RII/DFFI

NAME B. Adkins G. Goff L. HarrisN. Peterka N. Pitoniak J. Rivera M. RuffinR. Womack R. Williams

DATE 1/20/2022 1/20/2022 1/20/2022 1/20/2022 1/20/2022 1/20/2022 1/20/2022 1/20/2022 1/27/2022

U.S. NUCLEAR REGULATORY COMMISSION Inspection Report

Docket Number: 07000143

License Number: SNM-124

Report Number: 07000143/2021004

Licensee: NUCLEAR FUEL SERVICES, INC.

Facility: Nuclear Fuel Services

Location: Erwin, TN

Inspection Dates: October 01, 2021 to December 31, 2021

Inspectors: B. Adkins, Sr. Fuel Facility Projects Inspector G. Goff, Fuel Facilities Inspector L. Harris, Senior Resident Inspector N. Peterka, Fuel Facility Inspector N. Pitoniak, Sr. Fuel Facility Project Inspector M. Ruffin, Fuel Facility Inspector R. Womack, Physical Security 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 a core inspection at Nuclear Fuel Services, 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 07000143/2021-003-00 30-Day Written Notification 88135.02 Closed of Violation (SNM-124 License Condition S-7)

2 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 Uranium-Oxide (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

88015 - Nuclear Criticality Safety

The inspectors evaluated selected aspects of the licensees nuclear criticality safety (NCS) program to verify compliance with selected portions of Title 10 of the Code of Federal Regulations, Part 70 (10 CFR 70), including Sections 70.24, 70.50, 70.61, 70.62, and Appendix A; 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 evaluations (NCSEs), associated control flowdowns, and calculations to verify compliance with 10 CFR 70 and applicable sections of the license application, specifically Chapter 5. Specifically, the inspectors interviewed licensee staff and reviewed the following NCSEs associated with Areas 600 and 700 of the Production Fuel Facility:

54X-08-0004, "Nuclear Criticality Safety Evaluation for Area 700 of the Production Fuel Facility," Revision 4, including the review of the what-if analysis, double contingency analysis, items relied on for safety (IROFS) control tables, SCALE computer models, and accident sequences associated with Enclosure 0704 (IROFS 4.1.47.8, 4.1.68, 4.1.69, 4.1.70, and 4.1.71) 54X-06-0024, "Nuclear Criticality Safety Evaluation for Area 600 of the Production Fuel Facility," Revision 3, including review of what-if analysis, normal, credible abnormal, and non-credible accident sequences.

Criticality Implementation (IP Section 02.02)

3 The inspectors selected engineered and administrative controls from the licensees integrated safety analysis (ISA) summary to verify implementation in accordance with 10 CFR 70 and applicable sections of the license application. Specifically, the inspectors reviewed process and system descriptions, performed plant walkdowns, interviewed licensee staff, and reviewed the following associated with the NCSEs listed above:

reviewed the following administrative controls and management measures (postings and operating procedures) for Area 700: IROFS FA7-15, FA7-28, FA7-30, FA7-31, and FA7-33 reviewed the following administrative controls and management measures (postings and field verification) for Area 600: IROFS FA6-001, FA6-002, FA6-003, and FA6-009 reviewed the control flowdown and field verification checklist for Area 700 to verify criticality safety dimensions (geometry control) were field-verified by NCS staff reviewed active engineered control IROFS FA6-005, an air operated spring return valve, and its associated surveillance test results

Criticality Operational Oversight (IP Section 02.03)

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

reviewed training records for one operator assigned to Area 700B to verify completion of annual criticality safety training (computer-based) reviewed training materials (lesson plan and exam) for the annual criticality safety training refresher training course (computer-based) reviewed operator qualification records for one operator assigned to Area 700B (initial and 3-year requalification) reviewed the third and fourth quarter NCSE Audit reports for calendar year 2021 reviewed Engineering Change Request (ECR) 20200491 and the role of NCS oversight in the configuration management process

Criticality Programmatic Oversight (IP Section 02.04)

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

qualification records for a licensee contractor assigned to a site project computer verification of SCALE 6.1 on a new NCS engineer's computer

Criticality Incident Response and Corrective Action (IP Section 02.05)

The inspectors reviewed the licensees criticality accident alarm system (CAAS) and problem identification, resolution, and corrective system (PIRCS) entries to verify

4 compliance with 10 CFR 70 and applicable sections of the license application. Specifically, the inspectors observed equipment, interviewed licensee staff, and reviewed the following:

54T-20-0005, "Estimation of the Potential Dose to Exposed Workers and Off-Site Members of the Public Resulting from an Accidental Criticality," Revision 3

recent revisions to criticality emergency response procedures NFS-HES-E-02, NFS-HS-E-03, NFS-HS-E-07, NFS-HS-E-08, and NFS-HS-E-09 21T-2-0328, "Maximum Fission Yield for a Criticality Accident at Nuclear Fuel Services," March 20, 2020 condition reports involving failed/degraded IROFS: PIRCS 84660, 84661, 84693, 84013, and 86672

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 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 routinely attended and reviewed the results of scheduled licensee meetings to determine plant status and awareness of site activities to ensure inspection resources were appropriately focused on those activities with the higher safety significance.

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.

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 the applicable provisions of 10 CFR Sections 40.60 (source material),

70.50 (mainly radiological events), 70.52 (criticality and safeguards events), 71.95

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

Written Event Report 07000143/2021-003-00, 30-Day Written Notification of Violation (SNM-124 License Condition S-7), dated December 2, 2021 (ADAMS ML21344A052): See "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.

ISA and Fire Protection Audits, Third Quarter 2021 Health Physics Audits/Inspections, Third Quarter 2021 Environmental Safety Inspections/Audits, Third Quarter 2021 Industrial Safety, Third Quarter 2021

Procedures (IP Section 03.08)

The inspectors reviewed and observed implementation of the procedure listed below to ensure 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:

LOA-2366C-051: Plant Process Equipment in Building 301

Radiation Work Permit (RWP) (IP Section 03.09)

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

SWP 21-14-033 302-800

88135.04 - Resident Inspection Program Operational Safety

The inspectors reviewed the material condition and as-found configuration of selected site structures, systems, and components (SSCs); reviewed corresponding documentation, and interviewed licensee personnel to verify compliance with 10 CFR Part 70 and the license application. The inspectors also verified whether the selected SSCs were available and reliable to adequately protect plant workers and the public during normal, off-normal, and accident conditions.

6 Operations Safety Walkdown (IP Section 03.01)

The inspectors evaluated the operational safety of systems and sub-systems associated with backflow prevention and process cooling water. The inspectors reviewed the following safety controls.

N302XXXXLSHPAW3 N302XXXXLSHNIA2 N306XXXXPSLDI01

88135.05 - Resident Inspection Program Fire Protection (Annual/Quarterly)

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

Fire Area Walkdown (IP Section 03.01)

The inspectors walked down and evaluated the two fire areas listed below:

Building 302 Building 303

88135.19 - Post Maintenance Testing

The inspectors evaluated post maintenance testing (PMT) activities to verify compliance with the license application, Chapter 11, Management Measures, and test procedures and/or work order 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 PMTs listed below by either direct observation of the tests or review of test results.

N302 XCONDEN0E01 N303DOORSEAL652, associated with Work Request 298783

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.

7 Surveillance and Calibration Testing (IP Section 03.01)

The inspectors reviewed the two surveillance and/or calibration tests listed below by either direct observation of the tests or review of test results.

N302XCOLUMN0101 N302VALVEBAA525

RADIOLOGICAL CONTROLS

88030 - Radiation Protection

The inspectors evaluated selected aspects of the licensees radiation protection (RP) program to verify compliance with selected portions of 10 CFR 19, 20, 40, 61, and 70; Chapter 4, "Radiation Protection," of the facilitys license application; and applicable licensee procedures.

Radiation Protection Program Implementation (IP Section 02.01)

The inspectors interviewed licensee staff and reviewed licensee procedures and other documentation related to the implementation of the RP and radioactive waste programs to verify compliance with 10 CFR 20.1101(a) and applicable license application sections.

Specifically, the inspectors reviewed documents and interviewed licensee staff concerning the following:

Section 2.3.5.2, "Radiation Protection Function," of the license application Chapter 4, "Radiation Protection," of the license application NFS Functional Organization Chart RP program procedures

Radiation Protection Program Review (IP Section 02.02)

The inspectors reviewed the licensees as low as reasonably achievable (ALARA) reports and audit and self-assessment records to verify compliance with 10 CFR 20.1101(c),

20.2102; and Section 11.5, "Audits and Assessments," of the license application.

Specifically, the inspectors reviewed the following:

Triennial RP Program Evaluation, August 2021 2021 1st Quarter Health Physics Audit for Unrestricted Release 2021 1st Quarter Health Physics Audit of Gaseous and Liquid Effluent Monitoring 2021 1st Quarter Health Physics Audit of the RP Program 2021 2nd Quarter Audit for Radiation Technician Training Program 2021 2nd Quarter Audit of the Stationary Air Sampling Program 2021 2nd Quarter Health Physics Audit of the NFS Internal Dosimetry Program 2021 2nd Quarter Health Physics Audit for Radiation Worker Training Program 2021 3rd Quarter Audit for Lapel Air Sampling Program 2020 4th Quarter ALARA Performance Report for Occupational Exposure

8 2021 2nd Quarter ALARA Performance Report for Occupational Exposure

Radiation Protection and Radioactive Waste Procedures (IP Section 02.03)

The inspectors assessed the licensees review and implementation of RP-related changes to plant procedures to verify compliance with 10 CFR 70.72 and Section 11.4.6, "Periodic Reviews of Procedures," of the license application. Specifically, the inspectors completed the following:

reviewed RP procedure changes interviewed licensee RP staff concerning procedure changes

Training (IP Section 02.04)

The inspectors interviewed licensee staff and reviewed records related to RP and radioactive waste training, training material, and procedures to verify compliance with 10 CFR 19.12, 19.13, 70.61(f)(2), and Section 4.5, "Training," of the license application.

Specifically, the inspectors conducted the following activities:

reviewed the following training procedures:

o NFS-HS-A-12, "Radiation Technician Training Procedure" o NFS-GH-919, "Radiological Safety Training Program" o NFS-GH-39, "Radiological Safety Training" interviewed licensee staff concerning the Radiation Technician and Radiological Safety training programs reviewed select training records of radiation technicians to verify they were trained in accordance with NFS-HS-A-12

Safety-Significant Events (IP Section 02.05)

The inspectors reviewed the licensees disposition of safety-significant events and PIRCS entries related to RP and radioactive waste to verify compliance with 10 CFR 20.2202(a),

20.2202(b), 20.2203, 70.50, and Part 70 Appendix A. Specifically, the inspectors reviewed documents and interviewed licensee staff concerning the following:

PIRCS 81168 PIRCS 84444

Radiation Work Permits (IP Section 02.06)

The inspectors interviewed licensee staff and reviewed SWPs to verify compliance with Section 4.4.6, "Safety Work Permit Program," of the license application and procedure NFS-GH-03, "Safety Work Permit." Specifically, the inspectors conducted the following activities:

interviewed RP staff about the implementation of SWPs conducted walkdowns and reviewed the following SWPs o 17978 o 17982 o 21-27-025 o 21-50-048

9 Instrument Calibration (IP Section 02.07)

The inspectors interviewed licensee staff and reviewed licensee procedures and other documentation for RP instrument calibration to verify compliance with 10 CFR 20.1501(b) and applicable sections of the license application (Section 4.7.12.3, "Equipment Storage, Maintenance, and Calibration"). Specifically, the inspectors performed the following activities:

reviewed examples of NFS-HS-A-05, Attachment A, "Instrument Calibration Record," Revision 21 interviewed instrumentation and calibration technicians regarding calibration schedules and calibration activities interviewed RP technicians regarding instrument use and tracking

Instruments and Equipment (IP Section 02.08)

The inspectors interviewed licensee staff and reviewed the licensees use of radiation detecting instruments and equipment to verify compliance with 10 CFR 20.1501(a), 70.24(b) and applicable sections of the license application (Section 4.7.12.3, "Equipment Storage, Maintenance, and Calibration"). Specifically, the inspectors performed the following activities:

reviewed Table 4-9, "Typical Radiation Detection Instruments/Systems used at NFS," of the license application and compared the list to equipment found in the field for appropriate use of radiation detection reviewed Table 4-10, "Types and Uses of Available Instruments," of the license application and compared the list to equipment found in the field and assigned for emergency preparedness for appropriate use of dose rate range

Posting (IP Section 02.09)

This inspection procedure section was completed during routine inspection activities conducted throughout the year by the NRC resident inspector under IP 88135.

Container Labeling (IP Section 02.10)

This inspection procedure section was completed during routine inspection activities conducted throughout the year by the NRC resident inspector under IP 88135.

Posting of Notices (IP Section 02.11)

This inspection procedure section was completed during routine inspection activities conducted throughout the year by the NRC resident inspector under IP 88135.

Access Control (IP Section 02.12)

The inspectors reviewed records and toured areas of the facility to verify that access to radiation areas was in compliance with Chapter 4, "Radiation Protection" of the license application. Specifically, the inspectors conducted the following activities:

10 verified dosimetry was required for individuals attempting to enter into the restricted area verified training records were required to be current for individuals attempting to enter into a restricted area conducted walkdowns and verified access points into radiation areas were posted with signage indicating the presence of radiological hazards

Licensed Material Control (IP Section 02.13)

The inspectors reviewed the licensee's measures to secure stored material to verify compliance with 10 CFR 20.1801. Specifically, the inspectors reviewed the licensee's sealed source program as documented in the "Sealed Sources (IP Section 2.16)"

section of this report.

Radiation Surveys (IP Section 02.14)

The inspectors interviewed licensee staff and reviewed records of the licensee's external radiation surveys to verify compliance with 10 CFR 20.1501(a), 20.2103, and Chapter 4, "Radiation Protection," of the license application. Specifically, the inspectors conducted the following activities:

interviewed RP Technicians regarding external radiation surveys reviewed survey records contained in monthly health physics reports

Contamination Control (IP Section 02.15)

The inspectors interviewed licensee staff and reviewed records of the licensee's contamination control measures to verify compliance with 10 CFR 20.1501(a), 20.1501(b),

and Chapter 4, "Radiation Protection," of the license application. Specifically, the inspectors conducted the following activities:

reviewed air sampling records interviewed licensee RP Technicians regarding contamination control measures in place reviewed monthly records of contamination surveys

Sealed Sources (IP Section 02.16)

The inspectors reviewed records of the licensee's storage and control of NRC-licensed sealed sources to verify compliance with 10 CFR 20.1903(c) and Section 4.8.3, "Sealed Sources," of the license application. Specifically, the inspectors conducted the following activities:

walked down various storage locations of sealed sources on-site to verify they were being stored in accordance with 10 CFR 20.1903(c) reviewed the latest sealed source leak test report interviewed licensee staff concerning the sealed source program

11 Occupational Dose Results (IP Section 02.17)

The inspectors reviewed records of the occupational doses assigned to workers to verify compliance with 10 CFR 20.1201 and 20.1208. Specifically, the inspectors conducted the following activities:

reviewed multiple Safety and Safeguard Review Committee meeting minutes for assigned doses to workers reviewed the licensees dose tracking software for calculation methodology and maximally assigned doses for workers interviewed staff to verify that no minors are employed at NFS interviewed staff and reviewed procedures related to requirements for Declared Pregnant Workers

Exposure Controls (IP Section 02.18)

The inspectors interviewed licensee staff and reviewed the process used to keep doses ALARA to verify compliance with 10 CFR 20.1101(b), 20.1701, 20.1702, and Section 4.7.4, "Radiation Exposure Control," of the license application. Specifically, the inspectors conducted the following activities:

interviewed health physics staff regarding exposure control and area monitoring methods reviewed records of stationary air samples walked down the respirator building to verify the licensee had respirators and cartridges available to use in the event respiratory protection was needed

Bioassay Program (IP Section 02.19)

The inspectors interviewed licensee staff, reviewed records, and observed aspects of the bioassay program to verify compliance with 10 CFR 20.1703, 20.2103, and applicable sections of the license application (Section 4.7.2.1, "Routine Monitoring"). Specifically, the inspectors conducted the following activities:

reviewed bioassay records summarized in monthly, quarterly, and annual health physics reports and ALARA committee review minutes interviewed staff regarding frequency and procedures for bioassays reviewed the licensee's dose calculation methodology for the inclusion of bioassay for internal exposure calculation

Whole Body Counting (IP Section 02.20)

The inspectors interviewed licensee staff and reviewed whole body counting records to verify compliance with the applicable sections of the license application (Section 4.7.2.2, "Operational Monitoring"). Specifically, the inspectors conducted the following activities:

reviewed the in-vivo lung count results summarized in monthly, quarterly, and annual health physics reports and ALARA committee review minutes reviewed recently completed whole body count results interviewed staff regarding frequency of whole body counts bioassays

12 reviewed the licensees dose calculation methodology for the inclusion of whole body counts for internal exposure calculation

Dosimetry (IP Section 02.21)

The inspectors interviewed licensee staff and reviewed dosimetry records to verify compliance with 10 CFR 20.1501(d), 20.1502(a), and applicable sections of the license application (Section 4.7.6, "External Radiation Exposure - Personnel Monitoring Program").

Specifically, the inspectors conducted the following activities:

reviewed the National Voluntary Laboratory Accreditation Program (NVLAP) accreditation for Mirion Dosimetry reviewed external dosimetry reports summarized in monthly, quarterly, and annual health physics reports and ALARA committee review minutes observed personnel dosimetry in use throughout the plant

Dose Assessment Programmatic Review (IP Section 02.22)

The inspectors interviewed licensee staff and reviewed records and calculations related to the licensees assessment of the dose to workers to verify compliance with 10 CFR 20.1202, 20.2106, and applicable sections of the license application (Section 4.7.9, "Radiation Exposure Assessment"). Specifically, the inspectors conducted the following activities:

interviewed staff and reviewed dose records to verify that dose was calculated in accordance with 10 CFR 20.1202 interviewed staff and reviewed dose calculation methodology, records, and submission to verify they complied with 10 CFR 20.2106 reviewed samples of NRC Form 5s generated by the licensee's dose assessment program

As Low As Reasonably Achievable (ALARA) (IP Section 02.23)

The inspectors interviewed licensee staff and reviewed records related to the implementation of the ALARA program to verify compliance with 10 CFR 20.1101(b) and Section 4.2, "ALARA Program," of the license application. Specifically, the inspectors conduced the following activities:

interviewed the ALARA Health Physicist concerning the ALARA program reviewed the ALARA program procedure (NFS-GH-932) reviewed the ALARA goals for 2021, the revised 2021 ALARA goal for the projects ALARA unit, and the ALARA goals of 2020 to verify they were being set in accordance with NFS-GH-932 reviewed the 2nd Quarter 2021 and 4th Quarter 2020 ALARA Performance Reports for occupational exposure reviewed safety review committee meeting minutes

13 88045 - Effluent Control and Environmental Protection

The inspectors evaluated selected aspects of the licensees environmental protection program to verify compliance with selected portions of 10 CFR 20, Part 40, Part 61, Part 70, and Chapter 9, "Environmental Protection," of the facilitys license application.

Program Implementation (IP Section 02.01)

The inspectors reviewed any significant changes to the effluent control and environmental protection program, discussed with the licensee any new unplanned releases or contamination identified, and screened the PIRCS to verify the program was being implemented in compliance with the license requirements. Specifically, the inspectors conducted the following activities:

reviewed NFS-GH-909, "Environmental Protection Program," Revision 11 reviewed the following PIRCS entries: 66840, 80935, 80938, 83723, 84849, and 84897 reviewed the latest organizational charts for the environmental program department and the radiological waste department interviewed the Environmental Program Manager to verify that personnel changes in the environmental program department since the last NRC inspection were consistent with the license application

Procedures (IP Section 02.02)

The inspectors selected a sample set of procedures revised since the last NRC inspection in this area to verify any safety-significant changes to procedures in the area of environmental protection were in compliance with the license requirements. Specifically, the inspectors selected the following procedures:

NFS-HS-A-110, "Calibration of Flow Measurement Device and Sensor in Sanitary Sewer," Revisions 3 and 4 NFS-HS-A-114, "Calibration of Flow Measurement Device and Sensor in Banner Spring and North West Ditch," Revisions 3 and 4 NFS-HS-B-10, "Routine Air and Stack Sampler Calibration," Revisions 15 and 16 NFS-HS-B-16, "Routine Sampling of Sanitary Sewer," Revisions 35 and 36 NFS-HS-B-20, "Routine Sampling of Environmental Media," Revisions 25 and 26 NFS-HS-B-73, "Analysis of Environmental Liquid and Environmental Air Samples," Revisions 16 and 17 NFS-HS-B-97, "Sampling of Banner Spring Branch and North West Storm Water Ditch," Revisions 2 and 3 NFS-HS-B-98, "Air Sampler Calibration and Maintenance," Revisions 3 and 4

Audits and Quality Assurance (IP Section 02.03)

The inspectors reviewed procedures, audits, and assessments associated with the environmental protection program that were completed since the last NRC inspection in this

14 area to verify compliance with the applicable requirements in Chapters 9 and 11 of the license application. Specifically, the inspectors completed the following activities:

reviewed the Triennial Radiological Environmental Safety Assessment conducted at NFS reviewed QA-20-12, "ALARA Performance Report for Environmental -

Radiological" (3rd quarter of 2020 through the 2nd Quarter of 2021) reviewed licensee actions to address audit findings

Event Review (IP Section 02.04)

The inspectors reviewed the licensees evaluation of safety-significant events in the area of environmental protection to verify compliance with 10 CFR 20 and license application requirements. Specifically, the inspectors reviewed the following:

PIRCS entries 66840 and 84849, both of which pertained to a well injection issue that occurred on September 9, 2021 PIRCS entries 80935 and 80938, both of which pertained to an exceedance of an in-house concentration limit for Stack 573 PIRCS entry 83723, which pertained to an exceedance of an in-house concentration limit for Stack 234

Training (IP Section 02.05)

The inspectors reviewed the licensees training program in the area of environmental protection to verify compliance with license application requirements. Specifically, the inspectors performed the following:

The inspectors interviewed licensee staff to determine whether changes to the environmental training program and organization since the last NRC environmental protection inspection were in compliance with the license requirements.

Radioactive Liquid Effluents (IP Section 02.06)

The inspectors observed operations, reviewed sample collection and analysis procedures, reviewed radiological effluent monitoring reports and monitoring records, and discussed the radioactive liquid effluent results with licensee staff to verify compliance with aspects of 10 CFR 20.2103 and the license application. Specifically, the inspectors completed the following activities:

observed collection of a sample from ground well 234-2 reviewed the following procedures:

o NFS-HS-A-114, "Calibration of Flow Measurement Device and Sensor in Banner Spring and North West Ditch," Revision 4 o NFS-HS-B-97, Banner Springs Branch & West Ditch Inspections o NFS-HS-B-97, Banner Springs Branch & West Ditch - daily flow inspections, quarterly inspections, monthly inspections, and bi-annual inspections reviewed the following records:

o flow meter calibrations for Banner Springs and the North West Ditch

15 (March 22, 2021) o daily flow records of the North West Storm Ditch and Banner Springs Branch (June 12 - August 30) o weekly equipment inspection records of the North West Storm Ditch and Banner Springs Branch (July-September 2021) o monthly equipment inspection records of the North West Storm Ditch and Banner Springs Branch (July-August 2021) o quarterly equipment inspection records of the North West Storm Ditch and Banner Springs Branch (January, April, July 2021) o weekly records of on-site and off-site water samples for Martin Creek (July - September, 2021) o monthly upstream and downstream water samples of the Nolichucky River (July and August, 2021) o 2021 storm water sampling results

Municipal Sanitary Sewer (IP Section 02.07)

The inspectors reviewed records related to the release of liquid effluents to sanitary sewers to verify compliance with 10 CFR 20.2003 and the license application. Specifically, the inspectors completed the following activities:

observed collection of the North West Ditch composite sewer sample reviewed the following procedures:

o NFS-HS-A-110, "Calibration of Flow Measurement Device and Sensor in Sanitary Sewer," Revision 4 o NFS-HS-B-16, "Routine Sampling of Sanitary Sewer," Revision 36 reviewed records of discharges to the sanitary sewer system

Radioactive Airborne Effluents (IP Section 02.08)

The inspectors observed operations, reviewed sample collection and analysis procedures, reviewed radiological effluent monitoring reports and monitoring records, and discussed the radioactive airborne effluent results with licensee staff to verify compliance with aspects of 10 CFR 20.1101, 10 CFR 20.2103, and the license application. Specifically, the inspectors completed the following activities:

observed collection/change-out of stack filters walked down the BLEU facility gaseous effluent discharge system reviewed the following procedures:

o NFS-HS-A-10, "Determining Gaseous Effluent Flow Rates and Demonstrating Isokinetic Sampling," Revision 11 o NFS-HS-B-10, "Routine Air and Stack Sampler Calibration," Revision 16 o NFS-HS-B-18, "Collection and Analysis of NFS Stack Samples,"

Revision 27 o NFS-GH-40, "Gaseous Effluent Action Points," Revision 10 reviewed the following records:

o records of gaseous effluent discharges measurements from the third quarter of calendar year 2020 through the second quarter of calendar year 2021

16 o records of calibrations of stack flowmeters and velocimeters over the past 12 months o records of daily stack collection sheets for July and August 2021 o annual stack velocity profile and flow rate measurement results from calendar years 2019 and 2020

Effluent Monitoring (IP Section 02.09)

The inspectors observed operations, reviewed records, and discussed maintenance of effluent monitoring equipment with the licensee to verify compliance with 10 CFR 20.1501(b), 10 CFR 20.2103, and the license application. Specifically, the inspectors completed the following activities:

reviewed the following documents:

o NFS-HS-A-54, "Effluent Control & Environmental Monitoring Action Levels and MDC Requirements," Revision 15 o NFS-HS-A-110, "Calibration of Flow Measurement Device and Sensor in Sanitary Sewer," Revision 4 o NFS-HS-A-114, "Calibration of Flow Measurement Device and Sensor in Banner Spring and North West Ditch," Revision 4 o NFS-HS-B-10, "Routine Air and Stack Sampler Calibration," Revision 16 o NFS-HS-B-98, "Air Sampler Calibration and Maintenance," Revision 4 reviewed monthly discharge monitoring reports (DMRs) for January - August 2021 reviewed calibration records for stack flow meters, velocimeters, and on-site and off-site environmental air samplers observed that the calibration stickers on environmental air samplers and stack air flow meters were within the correct date range

Semiannual Effluent Reports (IP Section 02.10)

The inspectors reviewed the licensees effluent monitoring report to verify compliance with the requirements of 10 CFR 70.59. Specifically, the inspectors completed the following activities:

reviewed and discussed with licensee staff the semiannual effluent reports from the last half of calendar year 2020 and the first half of calendar year 2021

Quality Control of Analytical Measurements (IP Section 02.11)

The inspectors observed analytical laboratory operations and reviewed records of sample methods to verify compliance with the quality control requirements in the license application.

Specifically, the inspectors completed the following activities:

interviewed on-site laboratory personnel regarding handling, acceptance/rejection criteria, and chain of custody reviewed the following procedures:

o NFS-HS-B-77, "Operation of the Tennelec Counting Systems,"

Revision 7

17 o NFS-HS-B-73, "Analysis of Environmental Liquid and Environmental Air Samples," Revision 16 reviewed the following records:

o QA-20-12, "Quality Assurance Plan for Environmental Safety," July 17, 2020 o Tennelec instrument calibration verification records (October 2020) o Tennelec background and efficiencies records (August - September 2021) o weekly balance and monthly pipette checks for the environmental laboratory

Public Dose Analysis (IP Section 02.12)

The inspectors reviewed dose assessment records and associated reports to verify compliance with 10 CFR 20.1301, 10 CFR 20.1302, and the reporting requirements of 10 CFR 20.2107. Specifically, the inspectors completed the following activities:

reviewed procedures for calculating public dose:

o NFS-HS-A-27, "Routine Estimation of Off-site Dose from Radioactive Gaseous Effluents," Revision 12 reviewed the following records:

o the environmental dosimeter occupancy factors, July 17, 2020 o the ALARA Performance Report for Environmental - Radiological - 3rd quarter of 2020 - 2nd quarter of 2021

Environmental Sampling (IP Section 02.13)

The inspectors reviewed environmental sampling records of surface water, sediment, soil, vegetation, ambient air, groundwater, direct radiation, and/or sanitary sewer sludge, as applicable, to verify compliance with 10 CFR 20.1501 and the license application.

Specifically, the inspectors completed the following activities:

observed well-counter sampling of Well 234-2 reviewed the following procedures:

o NFS-HS-B-20, "Routine Sampling of Environmental Media," Revision 26 o NFS-HS-B-73, "Analysis of Environmental Liquid and Environmental Air Samples," Revision 17 reviewed the following records:

o calibration of on-site and off-site air sample flow meters (March 2021) o weekly records of the on-site and off-site environmental air samplers (July 2021) reviewed weekly (July - September 2021) and quarterly (2021) environmental air, water, soil, sediment, and vegetations sample sheets

18 Minimizing Facility and Environmental Contamination and Facilitating Decommissioning (IP Section 02.14)

The inspectors reviewed decommissioning records to verify compliance with 10 CFR 70.25(g) and 10 CFR 20.1406. Specifically, the inspectors performed the following activities:

reviewed documents describing the status of licensee's response to environmental spills, clean-ups, and soil remediation interviewed the Decommissioning Environmental Unit Manager regarding decommissioning activities

Radioactive Waste Classification, Characterization, and Storage (IP Section 02.15)

The inspectors reviewed documentation and records of facility activities and observed posting and labeling of storage areas and containers to verify compliance with the requirements of 10 CFR 61.55 and the license application. Specifically, the inspectors performed the following activities:

reviewed the following radioactive waste procedures and form for waste classification:

o NFS-WST-010, "Waste Certification Program Plan," Revision 6 o NFS-WST-038, "QAPP for Waste Control Specialists," Revision 1 o FM-NFS-GH-38-A, "Request for Waste Determination," Revision 3 reviewed the following radioactive waste procedures for waste characterization:

o NFS-GH-38, "Identification and Handling of Potential Hazardous Waste," Revision 8 o NFS-WST-021, "NFS Waste Characterization Implementation Plan,"

Revision 12 reviewed the following radioactive waste procedure for waste storage: NFS-ACC-32, "Building 310 Storage Procedure," Revision 26 walked down the radioactive waste storage area and observed the physical condition of waste containers, stacking of the waste containers, and labeling of the waste containers

Waste Burial (IP Section 02.16)

The inspectors interviewed NFS personnel regarding buried waste on-site and determined that this inspection procedure section did not apply.

Effluent Treatment (IP Section 02.17)

The inspectors conducted walkdowns and observations and reviewed records of on-site waste treatment facilities and airborne effluent scrubbers and filters to verify compliance with the license application. Specifically, the inspectors completed the following activities:

interviewed the on-site laboratory custodian regarding handling of samples and chain of custody interviewed the personnel responsible for airborne effluent filtration and

19 scrubbing interviewed the personnel responsible for liquid effluent filtration and purification reviewed records of gaseous effluent releases, liquid effluent releases, and releases to the sanitary sewer

FACILITY SUPPORT

88070 - Permanent Plant Modifications

The inspectors conducted a review to verify the licensee had established and implemented a configuration management system to evaluate, implement, and track changes to the facility in accordance with the applicable requirements in 10 CFR 70.72 and the license application, Chapter 11, Management Measures. The inspectors review also verified the licensee had established management measures for changes to the facility in accordance with 10 CFR 70, Subpart H and the license application, and that modifications involving new processes met the requirements in 10 CFR 70.64.

Sample Selection (IP Section 02.01)

The inspectors reviewed licensing documents, changes the licensee determined did not require pre-NRC approval under 10 CFR 70.72, and changes that affected the ISA summary to select changes/modifications to review. To assess whether the licensee conducted evaluations according to their established configuration management system, the inspectors selected the following plant modifications, identified as ECRs to review:

ECR-20213488, ECR-20201477, ECR-20200265, ECR-20190575, ECR-20213472, ECR-20200590, ECR-20200589, and ECR-20200102

Facility Change/Modification Process (IP Section 02.02)

The inspectors reviewed the selected modifications listed above to verify the licensee established a configuration management system in accordance with 10 CFR 70.72 and the conditions of the license. Specifically, the inspectors conducted the inspection activities listed below:

reviewed the following procedures to verify the configuration management system was documented in written procedures and the procedures addressed the aspects in 10 CFR 70.72(a) o NFS-TS-009, Configuration Management Process Change, Revision 9 o NFS-TS-0012, Status and Release of process Starting Materials, Revision 4 o NFS-GH-901, Configuration Management program, Revision 23 o NFS-CM-004, NFS Change Control Process, Revision 22 o NFS-ENG-010, Acceptance Testing Program, Revision 6 o NFS-HS-A-67, Documenting the Safety and Regulatory Review of Facility Changes, Revision 15 interviewed licensee staff, performed walkdowns of the BPF, the FMF, and the laboratory, and reviewed the selected ECRs to verify the licensees evaluation of changes provided valid technical bases to determine whether an

20 amendment to the license was required based on the criteria in 10 CFR 70.72(c) reviewed facility documentation associated with the selected ECRs to verify the affected documents were updated promptly in accordance with 10 CFR 70.72(e) or the timeframe outlined in the license reviewed configuration management system records to verify the licensee submitted a summary with facility changes and revised ISA Summary pages to the NRC in accordance with 10 CFR 70.72(d) reviewed equivalency evaluation for ECR-20200265 reviewed EA-NFS-2021, Triennial Audit of Configuration Management, dated November 2, 2021

Management Measures (IP Section 02.03)

For the selected modifications listed in IP Section 02.01, the inspectors reviewed the management measures established for affected IROFS (or credited safety controls) to verify the management measures ensured the IROFS (or credited safety controls) were available and reliable to perform their intended function as required by 10 CFR 70.61 and the license.

Specifically, the inspectors conducted the inspection activities listed below:

interviewed licensee staff and reviewed change management procedures to verify the licensee implemented the aspects described in configuration management system procedures and the license application interviewed licensee staff and reviewed affected procedures to verify the licensee followed the procedure control process in accordance with the license reviewed the following PMT procedures to verify they ensured adequate implementation of the design and functionality of the associated systems:

o PMT WR290576 o PMT WR290101 o PMT WR294809 o PMT WR281877 o Test Plan 71T-20-0602 reviewed maintenance and surveillance records of selected modifications to verify the licensee established periodic maintenance and surveillance testing in accordance with the license o IROFS 300-004/300-005 o IROFS 302/303-900 o SRE N303XDRAINH0401 interviewed licensee staff and reviewed qualification and training records to verify the staff involved in facility changes were qualified in accordance with the license and plant procedures reviewed condition reports to determine whether the licensee identified and corrected configuration management, post modification testing, and/or plant modification issues in accordance with the corrective action program provisions described in the license application conducted walkdowns of the BPF, FMF, and the laboratory

21 License Application Changes (IP Section 02.04)

For the selected modifications listed in IP Section 02.01, the inspectors interviewed licensee staff and reviewed applicable sections of the license application to verify the licensee evaluated license application changes and conducted NRC pre-approval screenings in accordance with the license requirements. Specifically, the inspectors conducted the inspection activity listed below:

reviewed the licensees procedure used to determine whether NRC pre-approval is required for license application changes (NFS-HS-A-67, "Documenting the Safety and Regulatory Review of Facility Changes") to verify whether the licensee evaluated license application changes in accordance with the conditions of the license

New Processes at Existing Facilities (IP Section 02.05)

The inspectors reviewed selected configuration management packages to verify that new facility processes, if any, addressed the requirements of 10 CFR 70.64 and evaluated whether proper NRC approval was needed for the change in accordance with 10 CFR 70.72 and the license conditions. Specifically, the inspectors conducted the inspection activities listed below:

interviewed licensee staff, performed walkdowns, and reviewed the configuration management package for modification ECR 20190575 to verify the licensee addressed the requirements in 10 CFR 70.64 and provided appropriate bases for not needing prior NRC approval reviewed the implementation of modification ECR 20190575

Records Retention (IP Section 02.06)

The inspectors reviewed a sample of plant documents impacted by the modifications listed in IP Section 02.01 to verify the licensee maintained records of facility changes in accordance with the license requirements and 10 CFR 70.72. The sample of documents included:

operating procedures o Standard Operating Procedure (SOP) 323, Revision 16 o SOP 409, Section 17A, Revision 5 o SOP 409, Section 13, Revision 27 o SOP 409, Section 12, Revision 37 training records o Engineering Design Authority (EDA) delegation of authority memo dated October 7, 2021 o EDA Qualification Card, NFSENG-EDA-QC-01, Revision 0 system drawings o 333-F0460-D, "BPF SX Sump Columns," Revision O o 110-E0019-D, "Power Layout Development Lab/Test Facility,"

Revision B o 333-I3297-D, "BLDG 333 Mezz level Fire Alarm System," Revision 0 ISA and ISA Summary

22 o 21X-21-0002, Revision 16 o 21X-21-0004, Revision 17 o 21X-19-0005, Revision 15 o 21X-21-0001, Revision 15 o 21T-21-0001, Revision 18 o 21X-21-0003, Revision 17 o 21X-20-0014, Revision 4

INSPECTION RESULTS

WER 30-Day Written Notification of Violation (SNM-124 License 88135.02 (Closed) Condition S-7)

WER 07000143/2021-003-00

==

Description:==

In September 2021, an NFS-authorized contractor was performing groundwater treatment activities at the NFS site using bioremediation technologies to mitigate tetrachloroethylene (PCE). The treatment involved the injection of Anaerobic BioChem Plus (ABC+) into ground water wells located on the North Site of the NFS property. On September 9, 2021, NFS personnel identified groundwater treatment chemicals surfacing in the storm water drainage system. The release was identified as a ground water treatment injection mixture, ABC+, which entered the storm water drainage system known as the west ditch that flows to Martin Creek. When NFS identified the release, all groundwater injections were stopped.

Water from the west ditch was pumped to an upland location on the North Site and allowed to soak into the ground to prevent the ABC+ mixture from further progressing to the west ditch and into Martin Creek. Spill pads and booms were also placed in the west ditch to capture any oily sheen present. Impacted algae, sediment, and rocks from the west ditch were manually removed as part of clean-up efforts. The licensee collected "grab samples" and did not identify gross radioactivity values in excess of regulatory limits. The licensee entered the event into the licensees PIRCS program (PIRCS 30604), conducted a general investigation, and developed a corrective action plan.

On September 9, 2021, NFS personnel verbally reported the issue to the Tennessee Department of Environment and Conservation (TDEC), followed by a written report on September 14. On November 4, 2021, TDEC issued a notice of violation for the subject storm water drainage system discharge. On December 2, 2021, NFS provided a 30-day written notification of the violation (ADAMS ML21344A052) to the NRC as required by SNM-124 License Condition S-7. The NRC reviewed the written report and did not identify any violations of NRC requirements based on the determination that the unauthorized storm water discharge did not involve NRC-regulated material or radiological release exceeding NRC regulatory limits. This item is considered closed.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

On January 19, 2022, the inspectors presented the core inspection results to Ronald Dailey and other members of the licensee staff.

23 On October 7, 2021, the inspectors presented the radiation protection and effluent control and environmental protection inspection results to Timothy Knowles and other members of the licensee staff.

On December 2, 2021, the inspectors presented the nuclear criticality safety and plant modifications inspection results to Ronald Dailey and other members of the licensee staff.

24 DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or Procedure Date 88015 Corrective Action 84660, 84661, Problem Identification, Resolution, and Correction System Various Documents 84693, 84460, 86669, 86672, 84013 Engineering ECR-202000491 Removal of 303, Area 600 Primary Equipment 4/30/2020 Changes Engineering 21T-20-0328 Maximum Fission Yield for a Criticality Accident at Nuclear 3/10/2020 Evaluations Fuel Services 54T-20-0005 Estimation of the Potential Dose to Exposed Workers and 3 Off-Site Members of the Public Resulting from an Accidental Criticality 54X-06-0024 NCSE for Area 600 of the Production Fuel Facility 3 54X-06-0025 Risk Index and IROFS Summary for Area 600 of the 2 Production Fuel Facility 54X-08-0004 NCSE for Area 700 of the Production Fuel Facility 4 54X-08-0005 Control Flowdown and Field Verification for Area 700 of the 4 Production Fuel Facility 54X-11-0003 Control Flowdown and Field Verification for Area 600 4 ECR-20200491 Removal of 303, Area 600 Primary Equipment 0 Miscellaneous NCSE Audits 27T-20-4029 General Employee Annual Safety Refresher Training - 2021 11/4/2020 27T-20-4087 Nuclear Fuel Services Annual NCS Refresher Training Test A

54T-18-0007 Verification of Computer Codes for NCS for Uranium 0 Systems with Enrichments up to 100 wt.% 235U: SCALE 6.1 with V7-238 Library from ENDF/B-VII N302VALVEBAB525 302-BA-B525 Annual Surveillance Test 1/4/2021 N302VALVEFVA601 302-FV-A601, 302-FY-A601, 302-HS-A601 Semi-Annual 7/19/2021 Surveillance Test SA-NCSREFRESH How to Avoid a Criticality Computer-Based Training 7/13/2022 Procedures NFS-HS-CL-10-07 NCSE Building 302 and 303 - Area 700 (U) 10 NFS-HS-E-02 Emergency Criticality Evaluation 49

25 Inspection Type Designation Description or Title Revision or Procedure Date NFS-HS-E-02 Emergency Criticality Evacuation 49 NFS-HS-E-03 Emergency Response Organization 37 NFS-HS-E-03 Emergency Response Organization 37 NFS-HS-E-07 On-Site Radiological Emergency Assessment 36 NFS-HS-E-07 On-Site Radiological Emergency Assessment 36 NFS-HS-E-08 Off-Site Radiological Emergency Assessment 32 NFS-HS-E-09 Off-Site Dose Projection for Radiological Emergency 31 NFS-HS-E-09 Off-Site Dose Projection for Radiological Emergency 32 SOP 401-06 FMF, Bldgs. 302/303, Area 600 1 SOP-401-07B Fuel Manufacturing Facility Area 700 Lot Preparation (U) 32 Work Orders 297691 Replace 302-LSH-PAW1 & PAW2 8/19/2021 88030 ALARA Plans 4th Quarter 2020 ALARA Performance Report for 3/4/2021 Occupational Exposure 2nd Quarter 2021 ALARA Performance Report for 9/2/2021 Occupational Exposure 21T-20-1060 ALARA Goals for January 1, 2021, through December 31, 1/7/2021 2021 Miscellaneous 21T-21-0425 Monthly Health Physics Report for April 2021 5/13/2021 21T-21-0502 HP Monthly Inspection - Building 330 WWTF, May 2021 6/4/2021 21T-21-0643 Monthly Radioactive Airborne Effluent Report - June 2021 7/8/2021 21T-21-0796 Monthly Health Physics Report for July 2021 8/16/2021 21T-21-0813 HP Inspection for Building 301, August 2021 8/26/2021 21T-21-0834 Monthly Health Physics Report for August 2021 9/15/2021 21T-21-0847 HP Inspections for building 304, September 2021 9/22/2021 HEA-02-03 Sealed Source Leak Test Report 5/21/2021 Procedures LOA-HS-21-002 Authorization to Deviate from NFS-HS-B-52 9/9/2021 LOA-HS-21-003 Authorization to Deviate from NFS-HS-A-21 Regarding 9/23/2021 Response Checks of Detectors NFS-GH-03 Safety Work Permit 21 NFS-GH-07 Respiratory Protection Program 23 NFS-GH-07-01 Respirator Storage and Acquisition 4 NFS-GH-07-03 Contaminant Maximum Use Concentration for Respiratory 1 Protection

26 Inspection Type Designation Description or Title Revision or Procedure Date NFS-GH-39 Radiological Safety Training 11 NFS-GH-63 Unrestricted Equipment/Item Release 3 NFS-GH-79 Sealed Source Program 3 NFS-GH-919 Radiological Safety Training Program 3 NFS-GH-932 ALARA Program 11 NFS-HS-A-12 Radiation Technician Training Procedure 13 NFS-HS-A-33 Verification of Representativeness of Work Area Air 7 Sampling Radiation Work SWP 17978 9/10/2021 Permits (RWPs) SWP 17982 9/17/2021 SWP 21-27-025 7/2/2021 SWP 21-50-048 9/22/2021 Self-Assessments Triennial RP Program Evaluation Conducted at Nuclear Fuel 8/19/2021 Services, Inc.

21T-21-0215 Monthly Health Physics Report for January 2021 2/15/2021 21T-21-0267 HP Audit of the RP Program, 1st Quarter 2021 3/9/2021 21T-21-0289 Monthly Health Physics Report for February 2021 3/16/2021 21T-21-0350 HP Audit of Gaseous and Liquid Effluent Monitoring, Q1, 3/30/2021 2021 21T-21-0370 Monthly Health Physics Report for March 2021 4/16/2021 21T-21-0371 HP Audit for Unrestricted Release, 1st Quarter 2021 4/20/2021 21T-21-0425 Monthly Health Physics Report for April 2021 5/13/2021 21T-21-0511 HP Audit of the Stationary Air Sampling Program, 2 Quarter, 6/08/2021 2021 21T-21-0532 Monthly Health Physics Report for May 2021 6/17/2021 21T-21-0691 HP Audit for Radiation Worker Training Program, 2nd 7/6/2021 Quarter 2021 21T-21-0692 HP Audit of the NFS Internal Dosimetry Program, 2nd 6/30/2021 Quarter 2021 21T-21-0695 2nd Quarter 2021 Audit of Radiation Worker Training 6/28/2021 Program 21T-21-0703 Monthly Health Physics Report for June 2021 7/15/2021 21T-21-0796 Monthly Health Physics Report for July 2021 8/16/2021

27 Inspection Type Designation Description or Title Revision or Procedure Date 21T-21-0834 Monthly Health Physics Report for August 2021 9/15/2021 21T-21-0855 Quarterly Audit for Lapel Air Sampling Program 9/28/2021 88045 ALARA Plans 2nd Quarter 2021 ALARA Performance Report for 9/02/2021 Environmental - Radiological Calculations Tennelec Background & Efficiencies 8/2021, 9/2021 Annual Stack Velocity Profile and Flow Rate Measurement 1/12/2021 Results - 2020 Annual Stack Velocity Profile and Flow Rate Measurement 1/15/2020 Results - 2019 Calibration Tennelec Instrument Calibration Verification 10/2018 -

Records 10/2020 Calibrations of Stack Flowmeters and Velocimeters 2020 and 2021 Calibration of On-site & Off-site Air Sample Flow Meters 3/2021 Corrective Action 66840 Well injection in West ditch Documents 80935 Stack 573 - Gaseous effluent exceeded in-house action level 80938 Stack 573 - Gaseous effluent exceeded in-house action level 83723 Stack 234 - Gaseous effluent exceeded in-house action level 848849 Well injection in West ditch 84897 Elevated water level in Nolichucky Miscellaneous NFS Environmental Protection Organizational Chart 2021 Stormwater Sampling Results 6/25/2021 Triennial Environmental Protection Audit 8/16 -

21/2021 Environmental Dosimeter Occupancy Factors 7/17/2020 Transportation & Waste Management Program 10/7/2021 Organizational Chart Monthly Discharge Monitoring Reports (DMRs) 1/1/2021 -

8/31/2021 FM-NFS-GH-38-A Request for Waste Determination 3 QA-20-12 Quality Assurance Plan for Environmental Safety 7/17/2020 Procedures NFS-ACC-032 Building 310 Storage Procedure 26

28 Inspection Type Designation Description or Title Revision or Procedure Date NFS-GH-38 Identification and Handling of Potential Hazardous Waste 8 NFS-GH-40 Gaseous Effluent Action Points 10 NFS-GH-909 Environmental Protection Program 11 NFS-HS-A-10 Determining Gaseous Effluent Flow Rates and 11 Demonstrating Isokinetic Sampling NFS-HS-A-110 Calibration of Flow Measurement Device and Sensor in 3 Sanitary Sewer NFS-HS-A-110 Calibration of Flow Measurement Device and Sensor in 4 Sanitary Sewer NFS-HS-A-114 Calibration of Flow Measurement Device and Sensor in 4 Banner Spring and North West Ditch NFS-HS-A-114 Calibration of Flow Measurement Device and Sensor in 3 Banner Spring and North West Ditch NFS-HS-A-27 Routine Estimation of Off-site Dose from Radioactive 12 Gaseous Effluents NFS-HS-A-54 Effluent Control & Environmental Monitoring Action Levels 15 and MDC Requirements NFS-HS-B-10 Routine Air and Stack Sampler Calibration 16 NFS-HS-B-10 Routine Air and Stack Sampler Calibration 15 NFS-HS-B-16 Routine Sampling of Sanitary Sewer 35 NFS-HS-B-16 Routine Sampling of Sanitary Sewer 36 NFS-HS-B-18 Collection and Analysis of NFS Stack Samples 27 NFS-HS-B-20 Routine Sampling of Environmental Media 26 NFS-HS-B-20 Routine Sampling of Environmental Media 25 NFS-HS-B-41 Routine Groundwater Sampling Procedure 33 NFS-HS-B-73 Analysis of Environmental Liquid and Environmental Air 16 Samples NFS-HS-B-73 Analysis of Environmental Liquid and Environmental Air 17 Samples NFS-HS-B-77 Operation of the Tennelec Counting Systems 7 NFS-HS-B-97 Sampling of Banner Spring Branch and North West Storm 2 Water Ditch NFS-HS-B-97 Sampling of Banner Spring Branch and North West Storm 3 Water Ditch

29 Inspection Type Designation Description or Title Revision or Procedure Date NFS-HS-B-98 Air Sampler Calibration and Maintenance 3 NFS-HS-B-98 Air Sampler Calibration and Maintenance 4 NFS-WST-010 Waste Certification Program Plan 6 NFS-WST-021 NFS Waste Characterization Implementation Plan 12 NFS-WST-038 QAPP for Waste Control Specialists 1 Self-Assessments Triennial Radiological Environmental Safety Assessment 8/16-19/2021 Conducted at Nuclear Fuel Service, Inc. (NFS) 88070 Corrective Action 81314, 81511, Problem Identification, Resolution, and Correction System various Documents 81342, 83954, 83914, 84178, 84874, 85101 Engineering ECR-20213488 Engineering Change Request 0 Changes Procedures NFS-CM-004 NFS Change Control Process 22 NFS-ENG-010 Acceptance Testing Program 6 NFS-GH-901 Configuration Management Program 23 NFS-HS-A-67 Documenting the Safety and Regulatory Review of Facility 15 Changes NFS-TS-009 Configuration Management of Process Change 9 NFS-TS-012 Status and Release of Process Starting Materials 4 Self-Assessments EA-NFS-2021 Triennial Audit of Configuration Management 11/3/2021 88135.02 Corrective Action 86898 Storage Racks 12/28/2021 Documents Resulting from Inspection 88135.04 Corrective Action 85162 Criticality Safety - LOA -2366C-051 10/5/2021 Documents Resulting from Inspection 88135.05 Corrective Action 85509 Fire Doors 11/8/2021 Documents 85510 Flammable Storage Cabinets 11/9/2021 Resulting from 85511 Fire Extinguisher Inspection 11/9/2021 Inspection Operability Fire Door Inspections 302 and 303

30 Inspection Type Designation Description or Title Revision or Procedure Date Evaluations FM-HS-B-95-02, Fire Barrier Inspection (302 and 303)

Rev 3 IROFS 300-General Fire Damper Tests 303 and 303 MFS-HS-B-70 Manual Pull Stations Annual (302 and 303)

NFS-GH-62-01 Control of Combustibles Monthly (302 and 303)

NFS-HS-B-11 Emergency Lights Monthly (302 and 303)

NFS-HS-B-70 Smoke Detectors Annual (302)

31