ML22201A535

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Framatome 2022-002 Integrated Quarterly Inspection Report
ML22201A535
Person / Time
Site: Framatome ANP Richland
Issue date: 07/21/2022
From: Eric Michel
NRC/RGN-II/DFFI/FFB2
To: Stephens L
Framatome
References
IR 2022002
Download: ML22201A535 (34)
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Text

July 21, 2022 Mr. Lance Stephens Site Manager Framatome Inc.

2101 Horn Rapids Road Richland, WA 99354

SUBJECT:

FRAMATOME-RICHLAND - NRC INSPECTION REPORT 07001257/2022002

Dear Mr. Stephens:

On April 27 and May 26, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed inspections at Framatome-Richland and 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, Signed by Michel, Eric on 07/21/22 Eric C. Michel, Chief Projects Branch 2 Division of Fuel Facility Inspection Docket No. 07001257 License No. SNM-1227

Enclosure:

As stated cc w/ encl: Distribution via LISTSERV

ML22201A535 X Non-Sensitive X Publicly Available X SUNSI Review Sensitive Non-Publicly Available OFFICE RII/DFFI RII/DFFI RII/DFFI RII/DFFI RII/DFFI NAME B. Adkins L. Cooke T. Sippel C. Taylor M. Toth DATE 07/19/2022 07/19/2022 07/19/2022 07/19/2022 07/19/2022 OFFICE RII/DFFI NAME E. Michel DATE O7/21/1022 U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number: 07001257 License Number: SNM-1227 Report Number: 07001257/2022002 Enterprise Identifier: I-2022-002-0065 Licensee: Framatome Inc.

Facility: Framatome-Richland Location: Richland, WA Inspection Dates: April 25-28, 2022, and May 23-27, 2022 Inspectors: B. Adkins, Senior (Sr.) Fuel Facilities Project Inspector L. Cooke, Fuel Facilities Inspector G. Goff, Fuel Facilities Inspector T. Sippel, Fuel Facilities Inspector C. Taylor, Sr. Fuel Facilities Project Inspector M. Toth, Sr. Enforcement Specialist Approved By: Eric C. Michel, Chief Projects Branch 2 Division of Fuel Facility Inspection Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting NRC inspections at Framatome-Richland, 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 07001257/2022-002-00 Gamma Monitors Non- 88015 Open Functional (EN 55897)

WER 07001257/2021-003-00 Unplanned Medical 88030 Closed Treatment of a Contaminated Worker (EN 55634) 2

PLANT STATUS The Framatome facility converts uranium hexafluoride (UF6) into uranium dioxide (UO2) for the fabrication of low-enriched fuel assemblies used in commercial light water reactors. During the inspection period, normal production activities were ongoing.

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

SAFETY OPERATIONS 88015 - Nuclear Criticality Safety The inspectors evaluated selected aspects of the licensees Nuclear Criticality Safety program to verify compliance with selected portions of 10 Code of Federal Regulation (CFR) 70, including 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 analyses (NCSAs), and associated assumptions and calculations, to verify compliance with 10 CFR 70 and applicable sections of the license application, including portions of 3.1.4, 3.1.5, 3.1.6, 5.3.4, and 5.4. Specifically, the inspectors interviewed licensee staff, walked down systems, and reviewed the following NCSAs:

  • E04-NCSA-810, "Dry Conversion Vaporization System," Version 14.0, reviewing the basis for why the licensee screened certain accident sequences as not credible (e.g., sequences 1.1, 1.2, 1.5, 1.6)
  • E04-NCSA-163, "Industrial Waste Water Treatment Facilities," Version 33.0, focusing on review of accident sequences 5.1 and 5.2, which cover uranium accumulation scenarios in the sand filters
  • E04-NCSA-163, "Industrial Waste Water Treatment Facilities," Version 34.0, focusing on review of new accident sequence 5.1, which covers uranium accumulation in the sand filters 3

Criticality Implementation (IP Section 02.02)

The inspectors selected engineered and administrative controls from the licensees integrated safety analysis (ISA) summary to verify proper implementation through a review of process and system descriptions, plant walkdowns, and interviews to verify compliance with 10 CFR 70 and applicable sections of the license application, including portions of 11.2.2. Specifically, the inspectors interviewed licensee staff and reviewed the following controls, and their management measures, associated with the NCSAs listed above:

  • Items Relied On For Safety (IROFS) 2302, Proportional Sampling and U Totalizing - TK-717 and TK-714, an administrative control to limit uranium accumulation, reviewed sampling data and calculations in FRM-20323 for 2021 and part of 2022
  • IROFS 2303, Alarm Response - TK-717 Gamma Monitor, an active engineered control to limit uranium accumulation, reviewed associated condition reports
  • IROFS 2309, Gamma Monitor and Interlock - Sand Filter, an active engineered control to limit uranium accumulation, reviewed associated condition reports and calibration and testing records
  • IROFS 2310, Independent Gamma Monitor and Interlock - Sand Filter, an active engineered control to limit uranium accumulation, reviewed associated condition reports and calibration and testing records
  • IROFS 2311, Alarm Response - TK-714 Gamma Monitor, an active engineered control to limit uranium accumulation, reviewed associated condition reports and calibration record
  • IROFS 2315, Sand Filter Backwash, an administrative control to limit uranium accumulation, reviewed sampling data and completion records Criticality Operational Oversight (IP Section 02.03)

The inspectors assessed the NCS staffs oversight of plant operators, procedures, and operations of systems involving special nuclear material to verify compliance with 10 CFR 70 and applicable sections of the license application, including portions of 5.3.10, 5.3.11 and 5.5. Specifically, the inspectors performed the following activities:

  • reviewed operations training and exams for NCS hazards and controls, including HRR-CRT-500003-021 through HRR-CRT-500003-028
  • interviewed licensee engineers and operations staff concerning criticality hazards and control methods, including monitoring for long-term accumulations in the Industrial Waste Water Treatment Facility
  • observed a licensee NCS engineer conduct an NCS walk through and reviewed recent NCS audit reports
  • interviewed dry conversion facility area operators concerning criticality hazards and control methods 4

Criticality Programmatic Oversight (IP Section 02.04)

The inspectors reviewed NCS program procedures and NCS staff qualifications to verify compliance with 10 CFR 70 and applicable sections of the license application, including portions of 2.2.5.1. Specifically, the inspectors interviewed licensee NCS staff and/or reviewed documents concerning the following:

  • reviewed qualification record and training requirements for criticality safety analysts
  • reviewed the recently revised procedure E04-04-003, "Criticality Safety Specialist Training & Qualification Program," Version 3.0
  • reviewed licensee procedure E15-03-015, "Procedures and Practices for Performing Hazards Analyses," Version 10 Criticality Incident Response and Corrective Action (IP Section 02.05)

The inspectors reviewed the licensees criticality accident alarm system (CAAS) and corrective action program (CAP) to verify compliance with 10 CFR 70 and applicable sections of the license application, including portions of 5.3.9, 5.3.10, 5.3.11, 5.5 and 11.6.1. Additionally, the inspectors followed-up on Written Event Report (WER) 07001247/2022-002-00, "Gamma Monitors Non-Functional (Event Notification (EN) 55897)"

related to the failure of two redundant gamma monitors on a sand filter. Specifically, the inspectors conducted walkdowns, reviewed documents, and interviewed licensee staff concerning the following:

  • NCS Infractions21-022, 22-003,22-004, 22-005,22-006, 22-007,22-009, 22-010; and condition reports (CR)-2016-1543, CR-2021-2767, CR-2022-1299, and CR-2022-1300
  • recent NCS evacuation drill records and performance for 2021 evacuation drills
  • operator training on what to do during a CAAS activation
  • NCS engineer training and support for the emergency response organization RADIOLOGICAL CONTROLS 88030 - Radiation Protection The inspectors evaluated selected aspects of the licensees radiation protection (RP) program and radiological waste (RW) program to verify compliance with selected portions of 10 CFR 19, 20, 61 and 70; Chapter 4, Radiation Protection, of the license application; Chapter 11, "Management Measures," of the 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 5

verify compliance with 10 CFR 20.1101(a) and Chapters 4 and 11 of the license application. Specifically, the inspectors performed the following activities:

  • attended daily morning meetings where RP was discussed by workers and observed the emphasis placed on personnel safety
  • reviewed MCP-30099, "General Radiation Protection Rules &

Recommendations," Version 7.0

  • reviewed E05-03-001, "Radiation Protection Standard," Version 5.0
  • interviewed the health physicists regarding the bioassay program and external dosimetry program
  • reviewed the training requirements and records for three health & safety technicians
  • reviewed the monthly Radiation Safety Committee Meeting minutes from the previous 13 months
  • observed radiological activities, such as contamination surveys and pre-job briefs, performed in the field
  • reviewed the schedule of radiological duties and activities
  • interviewed the supervisor for radiological safety regarding his staff's roles and responsibilities
  • reviewed records of radiation surveys as listed in the "Documents Reviewed" section below
  • reviewed audits and assessments as listed in the "Documents Reviewed" section below Radiation Protection Program Review (IP Section 02.02)

The inspectors reviewed the licensees as low as reasonably achievable (ALARA) report and audits/assessment records to verify compliance with 10 CFR 20.1101(c) and 20.2102 and section 11.7 of the license application. Specifically, the inspector performed the following activities:

  • reviewed E05-01-023, The ALARA Report - January 1 - December 31, 2020, Version 1.0
  • reviewed monthly audits of the radiation protection program
  • reviewed a 2022 audit of the radioactive waste program
  • verified that records for the radiation protection audits and radioactive waste program audits are being maintained
  • verified that findings or observations from audits and assessments are being entered into the corrective action program and are being tracked to completion Radiation Protection and Radioactive Waste Procedures (IP Section 02.03)

The inspectors assessed the licensees procedure review process to verify compliance with sections 4.4 and 11.4 of the license application. Specifically, the inspectors reviewed the following procedures:

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  • AID-10110, Reference 116 Ludlum Model 2241 Calibration, Version 6.0
  • AID-10409, Reference 1083 Canberra Argos - 4AB & 5AB, Personnel Contamination Monitors, Version 5.1
  • AID-10837, Operator Aid Reference 1191 Mirion NCD Model EDAC3, Version 1.0
  • E05-03-001, Radiation Protection Standard, Version 5.0
  • E12-01-003, Environmental, Health, Safety & Licensing Audit and Assessment Program, Version 11.0
  • FRM-30532-A, Annual Radioactive Waste Handling Audit Checklist, Version 2.0
  • MCP-30051, Contractor Health and Safety Requirements, Version 12
  • MCP-30099, General Radiation Protection Rules & Recommendations, Version 7.0
  • MCP-30107, Radiation Job Permit, Version 7.0
  • SOP-40015, Routine Urine Sampling Program, Version 14.0
  • SOP-40016, In-Vivo Counting Program, Version 11.0
  • SOP-40047, Personnel Contamination Survey Checks, Version 9.0
  • SOP-40051, Decontamination of Personnel & Personal Clothing & Effects, Version 8.0
  • SOP-40052, Treatment of Injuries, Version 11.01
  • SOP-40174, General Facility Radiation Work Procedure, Version 31.0
  • SOP-40200, In-Plant Air Sampling, Version 19.0
  • SOP-41159, HST Incident Response, Version 3.0 Training (IP Section 02.04)

The inspectors interviewed licensee staff and reviewed RP and radioactive waste-related training records and frequencies to verify compliance with 10 CFR 19.12 and section 11.3 of the license application. Specifically, the inspectors performed the following activities:

  • reviewed training for the newest radiological waste employee Safety-Significant Events (IP Section 02.05)

The inspectors reviewed the licensees review of safety-significant events and RP and radioactive waste-related CAP entries to verify compliance with 10 CFR 20.2202, 10 CFR 70.50, Part 70 Appendix A, and section 11.6 of the license application. Additionally, the inspectors followed-up on an WER related to EN 55897. Specifically, the inspectors performed the following activities:

  • reviewed CR-2021-2762, -01, -02, apparent cause analysis; UF6 Release in the Autoclave Room
  • reviewed CR-2021-2766, -01, -02, -03, apparent cause analysis; SURF NOx Release from Powder Dissolver 320A
  • reviewed CR-2022-0268, -01, -02, -03; Lapel Requirements Unclear in Radiological Zones During Off-shifts 7
  • reviewed CR-2022-0268; Two Visitors Found without TLD Written as a Result of the On-Site Inspection)
  • reviewed CR-2022-0358; Doghouse Left of off Tk-906 Sandpiper in UNH Room 101A - IROFS 740 Failed
  • For EN 55897, walked down the affected section of the Ammonia Recovery Facility (ARF) and interviewed the plant engineer and process engineer for the ARF Radiation Work Permits (IP Section 02.06)

The inspectors interviewed licensee staff and reviewed radiological job permits (RJPs) to verify compliance with section 4.4 the license application. Specifically, the inspectors performed the following activities:

  • observed the daily pre-job brief and status report for work conducted under RJP, "D&D GSUR"
  • reviewed the following RJPs:

o D&D GSUR, 12/07/2021 - 12/31/2022 o Decommission ANF-250s in Warehouse 2, 12/07/2021 - 12/31/2022 o Opening the Interior VRF Roll-up Door While on Respiratory Protection, 06/23/2021 - 12/31/2022 o Downloading Scrap (TBF-XI and NPC Containers) in the DCF Hot Shop, 04/20/201 - 12/31/2022 o Decommission LUR Poly Tanks, 12/07/2021 - 12/31/2022 o D&D in LUR, 10/21/2021 - 12/31/2022 Instrument Calibration (IP Section 02.07)

The inspectors interviewed licensee staff and reviewed licensee procedures and other documentation for RP instrument calibration and the CAAS to verify compliance with 10 CFR 20.1501(c), 10 CFR 70.24, and sections 4.7.1 and 11.8 of the license application. Specifically, the inspectors performed the following activities:

  • observed the calibration of the Argos 4AB personnel contamination monitor in the Dry Conversion Facility Men's Changeroom under work order 13556227
  • observed that calibration labels were placed on survey instruments used at step-off pads and instruments were within calibration
  • walked down the on-site calibration lab to verify instruments used to perform calibrations on RP equipment were within calibration
  • walked down the CAAS to verify functionality and that calibration labels were current
  • reviewed certificates stating that calibration sources were traceable to a National Institute of Science and Technology (NIST) standard
  • reviewed the following instrument calibration records:

o Model 1000 SN 17550.48 o Model 177 SN 17522.63 o Model 2000 SN 17550.41 o Model 2241 SN 17522.18 8

o Model 3 SN 17510.91 o Model 3001 SN 17520.39 o Model 5792 SN 17510.54 o Model E-140 SN 17520.61 o Model E-520 SN 17510.84 o Model MicroRem SN 17510.55 o Model NP-2 SN 17510.21; 5099 Instruments and Equipment (IP Section 02.08)

The inspectors reviewed the licensees use of radiation detecting instruments and equipment to verify compliance with 10 CFR 20.1501(a) and section 4.7.5 of the license application. Specifically, the inspectors performed the following activities:

  • observed personnel contamination monitors properly function and were within calibration
  • verified selected survey instruments for alpha, beta, gamma, and neutron radiation were functional and within calibration Posting (IP Section 02.09)

The inspectors observed the posting of radiation areas, high radiation areas, and radioactive material storage areas to verify compliance with 10 CFR 20.1902, 20.1904, and section 4.8.4 of the license application. Specifically, the inspectors performed the following activities:

  • observed the postings for radiation areas in the processing areas, storage areas, laboratories, waste recovery areas, and waste storage areas
  • observed postings for airborne radioactivity areas
  • walked down the calibration laboratory to verify the posting for a high radiation area Container Labeling (IP Section 02.10)

The inspectors confirmed the exemption to the labeling requirement of 10 CFR 20.1904 for packages and containers that contain radioactive material per section 1.2.5 of the license application. Specifically, the inspectors:

  • observed the licensee's posting exemption, "Every container or vessel in this area, unless otherwise identified, may contain radioactive material" was thoroughly distributed throughout the site Posting of Notices (IP Section 02.11)

The inspectors observed the Posting of Notices to verify compliance with 10 CFR 19.11.

Specifically, the inspectors:

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  • observed that NRC Form 3 was posted in high pedestrian traffic areas, i.e.,

the West Gate and the North Gate entries and exits points Access Control (IP Section 02.12)

The inspectors observed the licensees access control measures to high radiation areas to verify compliance with 10 CFR 20.1601. Specifically, the inspectors performed the following activities:

  • observed that access to a high radiation area, the calibration laboratory, was behind a locked chain linked door and fence
  • interviewed the calibration technician about potential high radiation levels in the laboratory and safety concerns
  • observed that the source of the high radiation area was well-contained in a thick concrete storage container under lock and key Licensed Material Control (IP Section 02.13)

The inspectors observed the licensees measures to secure stored material and control and maintain constant surveillance of licensed material not in storage to verify compliance with 10 CFR 20.1801 and 20.1802. Specifically, the inspectors observed the following activities:

  • storage of source buttons in the health & safety technicians' office
  • usage and control of source buttons for survey meters located at step-off pads (exits) for radiologically controlled areas by having these source buttons attached via a string and/or stored in a sleeve on the survey meter Radiation Surveys (IP Section 02.14)

The inspectors reviewed records of the licensees external radiation surveys and retention of these records to verify compliance with 10 CFR 20.1501(a), 20.1501(b), 20.1902, 20.2103, and section 4.7.1 of the license application. Specifically, the inspectors performed the following activities:

  • reviewed the following radiation surveys:

o M-20220105-25 o M-20220204-10 o M-20220311-37 o M-20220415-8 o M-20220422-27 o M-20220503-26 o M-20220506-8

  • interviewed RP staff regarding the retention of these records and noted that such records are retained for the life of the facility 10

Contamination Control (IP Section 02.15)

The inspectors observed contamination surveys and reviewed records of the licensees contamination control measures to verify compliance with 10 CFR 20.1501(a), 20.1501(b),

20.1902, 20.2103, and section 4.7.5 of the license application. Specifically, the inspectors performed the following activities:

  • observed a daily contamination survey within the Specialty Fuels Building
  • reviewed the following contamination records:

o M-20220510-15 o M-20220514-12 o M-20220523-7 o M-20220523-15

  • interviewed RP staff regarding the retention of these records and noted that such records are retained for the life of the facility Sealed Sources (IP Section 02.16)

The inspectors observed the licensee's sealed source program is entirely under the Washington state license and determined this inspection procedure section did not apply.

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 section 4.7 of the license application. Specifically, the inspectors:

  • reviewed the dose records on NRC Form 5 for site employees and contractors expected to receive greater than 100 mrem in a calendar year.

Exposure Controls (IP Section 02.18)

The inspectors interviewed licensee staff and observed engineering controls used keep doses ALARA by controlling the concentration of radioactive material in air or limiting intake to verify compliance with 10 CFR 20.1101(b), 20.1701, 20.1702, and sections 4.7.2 and 4.7.3 of the license application. Specifically, the inspectors observed the following activities:

  • usage of containment units such as gloveboxes and hoods
  • ventilation systems drew air from cleaner areas to more contaminated areas
  • usage of breathing zone lapels and respirators
  • pre-job briefing for repairs to the L1 Calciner Damaged Cage in which workers discussed the need for respiratory protection Bioassay Program (IP Section 02.19)

The inspectors reviewed the bioassay program to verify compliance with 10 CFR 20.1502(b) and section 4.7.3 of the license application. Specifically, the inspectors performed the following activities:

  • interviewed licensee staff regarding the off-site contractor that administers the bioassay program
  • reviewed urinalysis reports related to individuals under a bioassay program
  • reviewed the bioassay procedure, MCP-30105, Bioassay Program, Revision 15.0 Whole Body Counting (IP Section 02.20)

The inspectors interviewed licensee staff and reviewed whole body counting records to verify compliance with the section 4.7.3 of the license application. Specifically, the inspectors:

  • interviewed licensee staff regarding the off-site contractor that administers the lung counting program and reviewed records of workers who had a lung count and whole body counts Dosimetry (IP Section 02.21)

The inspectors interviewed licensee staff, observed dosimetry being used, and reviewed dosimetry records to verify compliance with 10 CFR 20.1501(d), 20.1502(a), and section 4.7.2 of the license application. Specifically, the inspectors performed the following activities:

  • observed plant personnel properly wearing dosimeters in the areas that processed or stored SNM
  • reviewed SOP-40026, "Personnel Dosimeter Control Program," Version 16.0
  • reviewed the National Voluntary Laboratory Accreditation Program (NVLAP) certification for the dosimeter processor 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 20.1502(b)(c) and 20.2106 and section 4.7 of the license application. Specifically, the inspectors:

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  • reviewed MCP-30104, "Personnel External Dosimetry Program," Version 14.0 and reviewed calendar year 2021 dosimetry records for workers.

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 of the license application. Specifically, the inspectors performed the following activities:

  • reviewed the 2020 ALARA Report
  • reviewed the Radiation Safety Committee Meeting minutes and slides from the previous 13 months
  • reviewed procedure MCP-30108, "ALARA Program," Version 10.0
  • interviewed RP staff on the concept and practice for practicing time, distance, and shielding in order to minimize dose 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, and Part 70, and 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 corrective action program in order to verify the environmental protection program was being implemented in compliance with license requirements. Specifically, the inspectors performed the following activities:

  • reviewed procedures:

o E10-08-002, "Organization and Administration," Version 7.0 o E10-08-009, "Environmental Protection," Version 4.0 o E11-01-003, "Environmental Standards," Version 9.0

  • reviewed the latest organizational chart for the environmental health and safety organization
  • interviewed the Environmental Program Manager to verify 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 changed since the last inspection and, if possible, observed the procedures in use to verify that safety-significant changes to 13

procedures in the area of environmental protection were in compliance with license requirements and 10 CFR 20. Specifically, the inspectors completed the following activities:

  • reviewed the following selected procedures:

o ADM-000006, "Document Control," Version 35 o SOP-40043, "Radioactive Gaseous Effluent Sampling," Version 27 o E05--03-001, "Radiation Standards," Version 5.0 o E-06-07-009, "Groundwater Monitoring," Version 2.0 o E12-03-042, "Environmental Surveillance," Version 3.0 o SOP-40043, "Air Sampling Monitoring," Version 9.0 o SOP-40382, "Solid Waste Packaging," Version.41 o SOP-40031, "Waste Effluent Monitoring," Version 18

  • observed safety technicians perform the following procedures:

o SOP-40043, "Air Sampling Monitoring, SOP-40043," Version 9.0 o SOP-40031,"Waste Effluent Monitoring, SOP-40031," Version 18 o E12-03-042, "Environmental Surveillance, E12-03-042," Version 3.0 o SOP-40043, "Radioactive Gaseous Effluent Sampling," Version 27 Audits and Quality Assurance (IP Section 02.03)

The inspectors reviewed procedures associated with the conduct of audits and assessments along with completed third-party and self-assessed audits and resulting corrective action entries assessed with the environmental protection program since the last inspection to verify compliance with license application requirements. Specifically, the inspectors reviewed following:

  • E12-03-042, "Environmental Surveillance (EHS&L Audit/Inspection (A/I)

Guide," Version 3.0

  • FRM -30235 A, "Annual Radioactive Waste Handling Audit Checklist," Version 2.0
  • EHS&L Audit/Inspection Schedule dated May 20, 2022
  • "US Fuel 21-28 Internal Audit Report," dated December 2021
  • "HP-7 Environmental Audit Third Quarter 2021"
  • "Annual Radioactive Waste Handling Audit," dated May 20, 2022
  • "Semi-Annual Environmental Monitoring Audit Summary," (Audit No. EMA-56)

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:

  • E18-01-001, External Reporting of Safety, Environmental, MC&A, and Security Events and Conditions," Version 2.0
  • SOP-41159, "HST Incident Response," Version 3.0 14
  • 1717-06, "Corrective Action Program Procedure," Version 17
  • CR 2022-004, "Wrong Procedure Instruction for Laundering that Caused PPE MFP Waste to Enter the UO2 Waste Area" 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 activities:

  • reviewed ADM-00003, "HST Training & Certification Procedure," Version 8.0
  • reviewed radiological worker training qualification, HRR-RAD-HST General, for two environmental safety technicians last hired into the environmental protection organization
  • interviewed licensee staff to determine whether changes to the environmental training program and organization since the last NRC environmental 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 locations of ground wells for GM 2, GM 10, GM 12
  • reviewed the following procedures:

o E-06-07-009, "Groundwater Monitoring," Version. 2.0 o SOP-40031, "Waste Effluent Monitoring," Version 18.0

  • reviewed a sample of liquid effluent discharge records for 2020 and 2021 for the plant effluent monitoring station to verify all results did not exceed the effluent concentration values in 10 CFR 20, Appendix B, Table 2
  • reviewed a sample of liquid effluent discharges records for liquid processes to the Waste Water Treatment Facility tanks to verify that the radioactive concentration in these discharges did not exceed the federal regulatory limits and licensee action levels 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:

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  • observed collection of the plant effluent monitor station composite sewer sample
  • reviewed the following procedures o SOP-40031, " Waste Effluent Monitoring and Sampling," Version 18
  • reviewed records of discharges to the sanitary sewer system to verify compliance with 10 CFR 20.2003 limits 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 for locations: K03A, K06, K21, K31A, K37, K46, K47, K49, K50, K55, K58, K60, K62
  • conducted a walkdown of the BLEU Facility gaseous effluent discharge system (Air Samplers: Z16, Z17, Z20, Z32, Z19, Z22, Z33, Z28, Z25, Z38, Z30, Z01, Z02, Z03, Z10, Z11, Z12, Z08, Z14, Z15, Z13)
  • reviewed the following procedures:

o SOP 40032, "Radioactive Gaseous Effluent Sampling," Version 27 o AID-30118 A, "Extracting, Uploading, and Retrieving Stack Flow Data and Report (Operator Aid)," Version 1.0 o CAPP88 stack data (July 2021 through January 2022)

  • reviewed the following records:

o records of gaseous effluent discharges measurements from the first quarter of calendar year 2021 through the first quarter of 2022 o records of calibration of stack flowmeters and velocimeters over the past 12 months o records of daily stack collection sheets from January through June 2021 Effluent Monitoring (IP Section 02.09)

The inspectors observed operations, reviewed items relied on for safety (IROFS) and associated surveillance packages and discussed the results with the licensee to verify compliance with Subpart H of 10 CFR 70, the license application, and the integrated safety analysis. Specifically, the inspectors completed the following activities:

  • reviewed IROFS supporting documentation:

o IROFS 960, HVAC Exhaust Systems E04-NCSA-660 Surveillance Records, "Ignition Sources Are Controlled and the Use and Storage of Combustible/Flammable Material" HEPA Filter Design Requirements o IROFS 000, UF6 Cylinder Receiving & Storage, E04-NCSA-000 16

Sample results for Sump Receiver Tank Sampling

  • observed composite monthly liquid effluent sampling at the Plant Effluent Monitoring Station to verify sampling was occurring prior to effluent release into sewer Semiannual Effluent Reports (IP Section 02.10)

The inspectors reviewed the licensees effluent monitoring report to verify compliance with the requirements of 10 CFR 40.65 and/or 10 CFR 70.59. Specifically, the inspectors completed the following activities:

  • reviewed MCP-30118, "Preparation of NRC & WDOC Semi-Annual Effluent Report," Version 8.0
  • interviewed licensee staff regarding the semiannual effluent reports for calendar years 2021 and 2020 to verify if the licensee specified the quantity of each of the principal radionuclides released to unrestricted areas in liquid and gaseous effluents during operation and estimated maximum potential annual radiation doses to the public as required by 10 CFR 70.59
  • reviewed semiannual effluent reports for the following reporting periods:

o NRC required reporting of Effluents 1st Half 2021 dated 8/31/21 o NRC required reporting of Effluents 2nd Half 2021 dated 2/22/22 o NRC required reporting of Effluents 1st Half 2020 dated 8/28/20 o NRC required reporting of Effluents 2nd Half 2020 dated 2/24/21 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 reviewed the following:

  • SOP-411108, "Analysis of Urine, Waste, and Other Matrices for Impurities and Relative Isotopic Abundance by Inductively Coupled Plasma Mass Spectrometry (IP-MS)," Version 4.0
  • AID-40562 B, "Laboratory Information Management System (LIMS) Validation, Approval, and Data Corrections," Version 6.0
  • MCP-30917, "LIMS Custom Report Software Design Specification," Version 4.0
  • calibration records for ISCO 4230 used for flowmeter liquid waste effluent monitoring 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 17

CFR 20.2107. Specifically, the inspectors completed the following activities to verify that the total dose to the individual likely to receive the highest dose from the licensed operation did not exceed the regulatory limits during 2020 and 2021.

  • reviewed E05-03-001, "Radiation Protection Standard," Version 5.0
  • reviewed E11-01-003, "Environmental Protection Standard," Version 9.0
  • reviewed MCP-30108, "ALARA Program," Version 10
  • reviewed AID-31333C, "Calculating Dose Using CAP88," Version 1.0
  • reviewed ALARA Report (January 1 through December 31, 2020)
  • interviewed licensee staff and reviewed the public dose assessment to verify that the total dose to the individual likely to receive the highest dose from the licensed operation did not exceed the regulatory limits during 2020 and 2021
  • reviewed the airborne portion of the public dose assessment to verify results were in compliance with the ALARA constraint required by 10 CFR 20.1101(d)

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, if applicable, to verify compliance with 10 CFR 20.1501 and the license application. Specifically, the inspectors completed the following activities:

  • reviewed procedures:

o SOP-40035, "Environmental Forage Sampling," Version 8.0 o SOP-40033, "Environmental Dosimetry," Version 13 o SOP-40034, "Environmental Surface Soil Sampling," Version 10 o E06-07-009, "Compliance Groundwater Monitoring Plan," Version 2.0 o SOP-40039, "Richland WWTF Sludge Sampling," Version 9.0

  • reviewed the following records o calibration of on-site and off-site air sample flow meters o 2021 Annual Groundwater Report for sampling dates June and September 2021 o monthly fence line surveys (April and May 2022) o monthly vegetation sample sheets (April and May 2022) o monthly ambient air samples (April and May 2022) o quarterly soil sample sheet (2nd quarter 2022)

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 18
  • reviewed SOP 411159, "HST Incident Responses," Version 3.0
  • interviewed the Environmental Manager regarding the site's 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, forms for waste classification and characterization, and waste storage:

o E06-04-006, "Waste Analysis Plan," Version 7.0 o SWI-40487 A, "Waste Generator Disposal Pathways," Version 7.0 o SOP-40383, "Waste Assay Operation," Version 10 o SOP-40382, "Solid Waste Packaging," Version 41 o SOP-40665, "Inspection and Release of Waste for Land Disposal," Version 6.1 o SOP-40386, "Special/Mixed/Hazardous/Dangerous Waste Handling and Storage," Version 13

  • walkdown the radioactive waste storage areas (Dangerous Waste Storage Facility (DWSF), Ammonium Diuranate (ADU) Conversion Waste Area and Modular Extraction Recovery Facility (MERF) and observed the physical condition of waste containers, stacking of waste containers and labeling of the waste containers in these areas Waste Burial (IP Section 02.16)

The inspectors reviewed documentation and records of radioactive waste buried onsite prior to January 1981 to verify compliance with 10 CFR 20.2108, if applicable. Specifically, the inspectors:

  • interviewed Framatome personnel regarding buried waste on-site and determined the inspection procedure section did not apply Effluent Treatment (IP Section 02.17)

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

  • walkdown of Waste Water Treatment Facility and stack filtration housing and associated duct work
  • reviewed specifications for sand filters systems used to treat waste water
  • interviewed personnel responsible for airborne effluent filtration and scrubbing
  • interviewed personnel responsible for liquid effluent filtration and purification 19
  • interviewed personnel regarding their response towards exceeding airborne and liquid action levels
  • reviewed records of gaseous effluent releases, liquid effluent releases, releases to the sanitary sewer
  • reviewed E06-07-009, "Compliance Groundwater Monitoring Plan," Version 2.0
  • reviewed SOP- 40747, "Startup Test for HEPA Filtered Exhaust Systems,"

Version 6.0

  • reviewed DOS test exhaust final filter (HEPA) records:

o MERF ES-HVAC K69 Exhaust System dated 4/4/22 o UO2 Filter HEPA K21-5-5 Final dated 4/1/22 o UO2 Filter HEPA K3-5-1 dated 3/1/22 FACILITY SUPPORT 88051 - Evaluation of Exercises and Drills The inspectors observed and evaluated the licensees graded biennial exercise conducted on April 27, 2022, as well as briefings and critiques involving both on-site and off-site participants, to verify compliance with 10 CFR 70.22(i)(3)(xii), the Emergency Plan, and Chapter 8 of the license application. The scenario involved a natural gas explosion in the UO2 boiler room that caused significant building damage and resulted in a spill of uranyl nitrate and uranium dioxide to the environment. Specifically, the explosion met the threshold for declaration of an alert due to the potential for onsite radiological consequences and resulted in significant injuries and death to site personnel. The explosion resulted in the need to implement onsite protective actions including partial evacuation of facilities and personnel accountability. Offsite fire and medical (ambulatory) agencies participated in the event response.

Exercise Planning (IP Section 02.01)

The inspectors reviewed the emergency exercise scenario, discussed the exercise objectives with licensee personnel, observed controller meetings, and walked down the plant areas before the exercise to verify compliance with the Emergency Plan, Emergency Plan Implementing Procedure, and 10 CFR 70.22(i)(3)(xii). The inspectors performed the following activities:

  • reviewed the frequency of exercises conducted by the licensee
  • reviewed the scenario as it related to probability for occurrence at Framatome and to testing all elements of the Emergency Plan
  • observed no pre-staging of equipment in preparation for the exercise
  • reviewed duties and responsibilities for exercise personnel including controllers, evaluators, and observers
  • attended the controllers' meeting for the emergency exercise
  • reviewed the objectives of the exercise and the expectations from responders
  • reviewed the confidentiality of the scenario and objectives
  • observed the post-drill critique for the emergency exercise 20

Exercise Execution and Emergency Plan Implementation (IP Section 02.02)

The inspectors observed the initiation of the emergency exercise, the activation of the Emergency Operations Center (EOC) and Plant Emergency Organization, classification of the event, notification of offsite response organizations, establishment of the incident command post, implementation of field response teams, and reviewed onsite and offsite communications, releases and notifications to verify compliance with the Emergency Plan, Emergency Plan Implementing Procedures, and 10 CFR 70.22(i)(3)(xii). The inspectors observed and reviewed the following:

  • licensees analysis of plant conditions including assessment and classification of the accident scenario within the allowable time limits
  • staffing for all EOC/emergency organization positions
  • protective action recommendations (PARs) implemented by the EOC/emergency organization
  • drafting of offsite notifications including a review of content and time of issuance
  • onsite communication to occupational workers as it related to protective action recommendations
  • occupational workers participation in protective actions and the process to conduct personnel accountability
  • press release approval and issuance
  • Emergency Director control of the EOC/emergency organization and drill
  • dose assessor use of RASCAL software
  • response coordinators recommendations regarding conditions for terminating the event and restarting normal operations
  • recovery and re-entry recommendations implemented by the EOC/emergency organization
  • members of the licensees emergency response team assembly at designated assembly areas and the arrival of off-site emergency responders including fire, EMT, and police
  • emergency response teams actions including rescue activities for casualties and assessment of the affected area
  • rescue personnel gave priority to the severity of the wounds/injuries over contamination surveying
  • response to emerging situations to address the exercise scenario and meet the exercise objectives
  • Incident Commander command and control of the emergency response team and coordination of actions with off-site emergency responders
  • Richland Fire Department simulating roadblocks
  • Washington Department of Health simulating offsite radiation monitoring and sampling
  • implementation of training by HST staff for the treatment of radiological contaminated individuals 21

Critiques, Exercise Control, and Identification and Resolution of Problems (IP Section 02.03)

The inspectors observed the staff critiques of the emergency exercise and reviewed the licensees related corrective action program entries to verify compliance with the Emergency Plan, Emergency Plan Implementing Procedures, and 10 CFR 70.22(i)(3)(xii). The inspectors reviewed and observed the following:

  • critiques conducted by the licensee in which both licensee participants and offsite responders provided comments
  • discussions pertaining to the satisfying of all objectives of the emergency exercise
  • documented deficiencies identified during critiques including items planned for entry into the licensees corrective action program
  • observed the annual incipient fire fighter training for members of the plant emergency response team INSPECTION RESULTS WER Gamma Monitors Non-Functional (EN 55897) 88015 (Discussed) WER 07001257/2022-002-00

Description:

On May 12, 2022, at approx. 7:10 pm (PDT) the licensee became aware that the monthly scheduled gamma monitor calibration check identified two gamma detectors (6801 and 6802) nonfunctional in the Ammonia Recovery Facility (ARF). The two redundant gamma detectors are identified as IROFS (2309 & 2310) and are used to monitor for gradual long-term accumulations of uranium from exceeding a safe mass in a sand filter tank V680 for the Wastewater Treatment system. Tank V680 is considered an unfavorable geometry tank.

The filter sand tank, V680, contains very low amounts of uranium that cannot be directly discharged to the municipal sewer. Upon discovery, the licensees supervision was notified and the affected ARF and Wastewater Treatment area was placed out of service until further investigation. The licensee reported the condition under the requirements of 10 CFR Part 70 Appendix A b(2) due to the two failed IROFS, however, the licensee later concluded that the performance requirements of 10 CFR 70.61 continued to be met and conservatively reported the issue.

During the week of 5/23, inspectors reviewed this event to confirm that the licensee had put the system back into a safe configuration. This review included conducting walkdowns in the Waste Water Treatment System, including the sand filters and the gamma monitors as well as interviewing licensee engineers and operators concerning the event and the subsequent corrective actions. Corrective actions included shutting down the system and isolating the tank in question. The licensee also stated they verified that other detectors of the same type elsewhere were functioning and logic in the control system was altered to detect failures of this type in the future.

22

This event is being tracked as WER 07001257/2022-001-00, "Gamma Monitors Non-Functional (EN 55897)" and will remain open.

WER Unplanned Medical Treatment of a Contaminated Worker 88030 (Discussed) (EN 55634)

WER 07001257/2021-003-00

Description:

On December 8, 2021, at approximately 0745 PST, an instrument technician was contaminated with uranyl nitrate solution while calibrating a pressure transmitter. The individual followed safety protocol by utilizing the emergency wash station, and, as a precaution, received a medical evaluation at Kadlec Regional Medical Center for skin exposure to nitric acid.

Prior to leaving the site, Framatome Health and Safety Technicians decontaminated the individual to below release limits with the exception of their hands. The individual's hands were placed inside gloves which were secured to their wrists prior to being transported. The worker was transported to an offsite medical facility accompanied by plant health physics personnel.

After being evaluated, the individual returned to Framatome where their hands were decontaminated to below release limits and returned to work. The process area where this work was being performed was cleaned and the equipment was secured. The event has been entered into the facility's corrective action system.

Framatome reported this event consistent with the requirements of 10 CFR 70.50(b)(3) and submitted a 30-day report (ML22007A359) as required by 10 CFR 70.50(c)(2). The Written Event Report was reviewed. No violations of NRC requirements were identified. This WER is closed.

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

  • On April 27, 2022, and May 26, 2022, the inspectors presented the NRC inspection results to Lance Stephens and other members of the licensee staff.

23

DOCUMENTS REVIEWED Inspection Type Designation Description or Title Revision or Procedure Date 88015 Calculations FRM-20323 IX Feed Tank Uranium Material Balance, 2022 data through Version 2.0 05/16 FRM-20323 IX Feed Tank Uranium Material Balance, 2021 data Version 2.0 Corrective Action CR-2016-1543, NCS related condition reports Various Documents CR-2021-2767, CR-2022-1299, CR-2022-1300 NCS Infraction 21-022 NCS Infraction 03/02/2022 22-003 NCS Infraction 03/02/2022 22-004 NCS Infraction 05/20/2022 22-010 NCS Infractions Various22-005, 22-006,22-007, 22-009 Drawings Industrial Wastewater Treatment Process Flow Diagram Part 11/21 1: Main Process Engineering IRM Request Form for C163I102-0009 and -0010 09/15/2016 Changes Engineering E04-NCSA-163 Industrial Waste Water Treatment Facilities Version 33.0 Evaluations E04-NCSA-163 Industrial Waste Water Treatment Facilities Version 34.0 E04-NCSA-810 Dry Conversion Vaporization System Version 14.0 Miscellaneous Criticality Worker Safety Refresher Exam List of PM C163I102 completions since March 2010 ARF Sand Drums since 2009, U content Email from M. Sand filter sample results 05/20/2022 Curtis Email from S. Justification for restart of the 700 side of ARF 05/19/2022 Nunez to T. Tate 24

Inspection Type Designation Description or Title Revision or Procedure Date HRR-CRT- Criticality Safety Analyst Criticality Safety Academic 07/07/2021 200000 Knowledge Confirmation HRR-CRT- Criticality Safety Analyst Criticality Safety Principles 07/07/2021 200001 Confirmation HRR-CRT- Criticality Safety Analyst Criticality Safety Skills Practical 07/07/2021 200002 Application Confirmation HRR-CRT- Evacuation/Accidents 03/23/2018 500003-021 HRR-CRT- NCS Controls 03/23/2018 500003-022 HRR-CRT- Factors that Affect Nuclear Criticality Neutron Production 03/23/2018 500003-023 HRR-CRT- Factors that Affect Nuclear Criticality Neutron Absorption 03/23/2018 500003-024 HRR-CRT- Factors that Affect Nuclear Criticality Neutron Escape 03/23/2018 500003-025 HRR-CRT- NCS Guide Rules and Generic Program Requirements 03/23/2018 500003-026 HRR-CRT- Nuclear Criticality Safety Annual Refresher Training 03/23/2018 500003-027 HRR-CRT- Practical Application of NCS Controls 03/23/2018 500003-028 JMD-21.008 Semi-Annual Criticality Evacuation Drill April 8, 2021 - After 05/14/2021 Action Report JMD-21.016 Semi-Annual Criticality Evacuation Drill October 14, 2021 - 11/18/2021 After Action Report Procedures C163I102 Calibration procedure for ARF gamma monitors Version 6 C163P102 SAMPLE SAND FILTER/U 6MO OPWA Rev. 4 E04-04-003 Criticality Safety Specialist Training & Qualification Program Version 3.0 E15-03-005 Procedures and Practices for Performing Hazards Analyses Version 10 Self-Assessments E04-07-202111 NCS Audit/Inspection Report - November 2021 12/8/2021 E04-07-202112 NCS Audit/Inspection Report - December 2021 01/21/2022 E04-07-202201 NCS Audit/Inspection Report - January 2022 02/23/2022 E04-07-202202 NCS Audit/Inspection Report - February 2022 03/17/2022 25

Inspection Type Designation Description or Title Revision or Procedure Date E04-07-202203 NCS Audit/Inspection Report - March 2022 04/18/2022 Work Orders Various work orders using C163P102, SAMPLE SAND Various FILTER/U 6MO OPWA, to sample sand filter Uranium dates in concentration after backwash 2020 to 2022 C163P104 IX Feed Interlock Checks 6 Mo IN Rev. 4 WO 13515190 C163P104 IX Feed Interlock Checks 6 Mo IN 07/17/2021 WO 13526361 C163I102-0010 Meter Rad Gamma 1 Mo IN 10/24/2021 WO 13539371 C163P104 IX Feed Interlock Checks 6 Mo IN 01/19/2022 WO 13547670 C163I102-0009 Meter Rad Gamma 1 Mo IN 03/01/2022 WO 13547671 C163I102-0010 Meter Rad Gamma 1 Mo IN 03/01/2022 WO 13551870 C163I102-0009 Meter Rad Gamma 1 Mo IN 04/07/2022 WO 13551871 C163I102-0010 Meter Rad Gamma 1 Mo IN 04/07/2022 WO 13556225 C163I102-0009 Meter Rad Gamma 1Mo IN 05/18/2022 WO 13558723 Manual Call - C163I102 05/17/2022 WO 13558724 Manual Call - C163I102 05/17/2022 88030 ALARA Plans E05-01-023 The ALARA Report -January 1, 2020 -December 31, 2020 Version 1.0 EHS&L Council Radiation Safety Committee Meeting Minutes 04/2021 -

04/2022 Calibration Order 13556227 Zone Alpha and Beta Calibration for Argos 4AB DCF Men's 05/25/2022 Records Changeroom Corrective Action CR-2022-1366 NAF Burnback hood, equipment malfunction resulted in 05/21/2022 Documents personnel contamination and airborne radioactivity above mask limits.

Miscellaneous Bioassay records (includes in vitro and in vivo) 2021-2022 Radiological Shift Turnover Logs 05/23/2022 to 05/25/2022 Training records for radiological waste personnel Daily Status Report of the Decontamination & 03/28/2022 -

Decommissioning of the Gadolinium Scrap Uranium 05/19/2022 Recovery Area Bioassay Whole Body Counts, Urinalysis Report, and Lung Counts 05/01/2021 -

Records 04/30/2022 E08-04-2.2 MOU - Kadlec Regional Medical Center Version 8.0 26

Inspection Type Designation Description or Title Revision or Procedure Date FRM-30051A Construction Contractor Health and Safety Agreement 04/21/2021 HRR-IND-100070 2022 Hands-On Fire Extinguisher Training For Hot Work Fire 05/25/2022 Watch Personnel MSP/PJB - 16499 Maintenance Work Permit/Pre-Job Briefing - Repair L1 05/24/2022 Calciner Damaged Cage National Statement of Accreditation for Landauer, Inc.

Voluntary Laboratory Accreditation Program (NVLAP)

NRC Form 5 Occupational Dose Record for a Monitoring Period Calendar Year 2021 Survey P- VSDS Personal Contamination Event Report 12/08/2021 20211208-1 WN-I062-1 State of Washington Radioactive Materials License Amendment Renewal (CC) No.73 Procedures ADM-00006 Administrative Procedure for Documentum REDS Version 35.0 Documents AID-10110 Reference 116 Ludlum Model 2241 Calibration Version 6.0 AID-10409 Reference 1083 Canberra Argos - 4AB & 5AB, Personnel Version 5.1 Contamination Monitors AID-10837 Operator Aid Reference 1191 Mirion NCD Model EDAC3 Version 1.0 E05-03-001 Radiation Protection Standard Version 5.0 E12-01-003 Environmental, Health, Safety & Licensing Audit and Version 11.0 Assessment Program FRM-30532 A Annual Radioactive Waste Handling Audit Checklist Version 2.0 MCP-30036 Respiratory Protection Program Version 20.0 MCP-30051 Contractor Health and Safety Requirements Version 12 MCP-30099 General Radiation Protection Rules & Recommendations Version 7.0 MCP-30100 Contamination Control Program for Equipment & Facilities Version 9.0 MCP-30102 Radiological Respiratory Protection Program Version 10.0 MCP-30103 Personnel Monitoring & Overchecks Version 6.0 MCP-30104 Personnel External Dosimetry Program Version 14.0 27

Inspection Type Designation Description or Title Revision or Procedure Date MCP-30105 Bioassay Program Version 15.0 MCP-30107 Radiation Job Permit Version 7.0 MCP-30108 ALARA Program Version 10.0 SOP-40015 Routine Urine Sampling Program Version 14.0 SOP-40016 In-Vivo Counting Program Version 11.0 SOP-40020 In-Plant Air Sampling Version 19.0 SOP-40026 Personnel Dosimeter Control Program Version 16.0 SOP-40046 Area/Facility Removable Contamination Control Version 11.0 SOP-40047 Personnel Contamination Survey Checks Version 9.0 SOP-40051 Decontamination of Personnel & Personal Clothing & Effects Version 8.0 SOP-40052 Treatment of Injuries Version 11.01 SOP-40058 Posting Requirements Version 5.2 SOP-40174 General Facility Radiation Work Procedure Version 31.0 SOP-40198 Respiratory Protection Version 13.0 SOP-40200 Escorting Individuals into Radiation Areas Rev. 10.0 SOP-41159 HST Incident Response Version 3.0 Radiation M-20220105-25 DCF UF6 Cylinder Dock beta gamma 01/05/2022 Surveys M-20220204-10 DCF UF6 Cylinder Dock beta gamma 02/04/2022 M-20220311-37 DCF UF6 Cylinder Dock beta gamma 03/11/2022 M-20220415-8 ELO Upstairs Lab 40 beta gamma 04/15/2022 M-20220422-27 DCF UF6 Cylinder Dock beta gamma 04/22/2022 M-20220503-26 SF Main Lobby, Hall, Stairs beta gamma 05/03/2022 M-20220506-8 SURF Glovebox Gloves beta gamma 05/06/2022 M-20220510-15 WHS Sea Land Storage Containers 05/01/2022 M-20220514-12 UO2 ADU Process Lower and Upper 05/17/2022 M-20220523-15 SF Daily Contamination Survey 05/23/2022 M-20220523-7 ADU Upper and Lower 05/23/2022 Radiation Work Radiation Job D&D GSUR 12/07/2021 -

Permits (RWPs) Permit 12/31/2022 Radiation Job Decommission ANF-250s in Warehouse 2 12/07/2021 -

Permit 12/31/2022 Radiation Job Opening the Interior VRF Roll-up Door While on Respiratory 06/23/2021 -

28

Inspection Type Designation Description or Title Revision or Procedure Date Permit Protection 12/31/2022 Radiation Job Downloading Scrap (TBF-XI and NPC Containers) in the Permit DCF Hot Shop Radiation Job Decommission LUR Poly Tanks 12/07/2021 -

Permit 12/31/2022 Radiation Job D&D in LUR 10/21/2021 -

Permit 12/31/2022 Self-Assessments Framatome Richland - Radiation Protection (RP) and July 6 - 9, Environmental Protection (ENVT) Audit 2021 E05-12-202201 Surveillance Audit Report (HP-1) - February 2022 Monthly Version 1.0 Audit E05-12-202202 Surveillance Audit Report (HP-1) - March 2022 Monthly Audit 03/01/2022 E05-12-202203 Surveillance Audit Reports (HP-1) - March 2022 Monthly 03/31/2022 Audit E05-12-202204 Surveillance Audit Reports (HP-1) - April 2022 Monthly Audit 04/29/2022 E05-16-202101 ALARA Audit Report (HP-5) Version 1.0 E05-26-202201 Instrument Audit Report (HP-15) - 2022 Audit Version 1.0 RDM-22-005 Annual Radioactive Waste Handling Audit 05/20/2022 Work Orders IG000053-0009 ES DETECTOR, NEUTRON CRITICALITY (13526215 - October NEUTRON 13526222) 2021 PROBE 5YR IN 88045 ALARA Plans E06-04-006 Waste Analysis Plan Version 7 Calibration 13493992 Flowmeter- North Fenceline Sampler 1 YR Calibration February 7, Records 2021 13497745 IG000027-003 Fenceline SAMP 1Y Calibration March 11, 2021 Order # ISCO Bubbler Flowmeter Model 4230 April 20, 13551795 2022 Order # ISCO Bubbler Flow Meter Model 4230 Calibration Record May 4, 2022 13556151 Corrective Action 2021-1620 Triennial Assessment of the RP and Environmental July 15, Documents Protection System 2021 2021-2410 UN Solution Spill Near MERF October 12, 2021 29

Inspection Type Designation Description or Title Revision or Procedure Date 2022-0004 Procedure for Laundering Caused MFP waste to be sent to December the the UO2 Waste Area 15, 2021 Engineering E04-NCSA-000 UF6 Cylinder Receiving & Storage Version 11 Evaluations E04-NCSA-960 HVAC Exhaust Systems Version 40 Miscellaneous Required Reporting of Effluent Per 10 CFR 70.59 (July 1 February 28, through December 31, 2021) 2022 Required Reporting of Effluents Per 10 CFR 70.59 (January August 31, through June 30, 2021) 2021 Required Reporting of Effluents Per 10 CFR 70.59 (January August 28, through June 30, 2020) 2020 Required Reporting of Effluents Per 10 CFR 70.59 (July February 24, through December 31, 2020) 2021 Environmental Forage Sample April 22, 2022 Environmental Richland WWTF Sludge Sample April 22, 2022 Environmental Dosimetry Sample April 6, 2022 Environmental Surface Soil Sample April 22, 2022 Environmental, Health, Safety & Licensing Organization May 2022 Chart 13543073 Flowmeter- North Fenceline Sampler Calibration 1 YR February 12, 2022 13547817 DOS Test Exhaust HEPA Filter K3-5-1 Final 2YR (Equipment March 19, US35553-20) 2022 13552044 DOS Test Exhaust Final HEPA Filter K21-5-1 2YR April 30, (Equipment US35575-01 2022 13552048 DOS Test Exhaust Final HEPA Filter K69-5-1 2YR April 30, (Equipment US355820) 2022 56650 & 56666 User Curriculum Status Group By User May 23, 2022 Procedures 1717-06 Corrective Action Program Revision 17 ADM-00003 HST Training & Certification Procedure Version 8 AID-40562 B LIMS Validation, Approval, and Data Corrections Version 6.0 30

Inspection Type Designation Description or Title Revision or Procedure Date E-06-07-009 Compliance Groundwater Monitoring Plan Version 2 E06-04-006 Waste Analysis Plan Version 7 E10-08-002 SNM-1227 - Chapter 2, Organization and Administration Version 7 E10-08-009 Environmental Protection Version4 E11-01-003 Environmental Standards Version 9 E12-03-042 Environmental Surveillance Version 3 MCP-30108 Management Control Procedure, ALARA Program Version 10.0 MCP-30118 Preparation of NRC & WDOH Semi-Annual Effluent Report Version 8 MCP-30386 Radioactive Solid Waste Handling Filter Designation List Version 9.0 MCP-30917 LIMS Custom Report Software Design Specification Version 4 SOP 40747 Startup Tests for HEPA Filter Exhaust Systems Version 6 SOP- 40043 Ambient Air Sampling for Radioactivity Version 9 SOP- 40386 Special/Mixed/Hazardous/Dangerous Waste Handling and Version 13 Storage SOP-40031 Waste Effluent Monitoring & Sampling Version 18 SOP-40032 Radioactive Gaseous Effluent Sampling Version 27 SOP-40382 Solid Waste Packaging Procedure Version 41 SOP-41108 Analysis of Urine, Waste and Other Matrices for Impurities Version 4 and Relative Isotopic Abundance by Inductively Coupled Plasma Mass Spectrometry (ICP-MS)

SOP-41159 HST Incident Response Version 3 SWI-40487 A Waste Generator Disposal Pathways Version 7 Self-Assessments Annual Radioactive Waste Handling Audit May 20, 2022 Semi-Annual Environmental Monitoring Audit Summary February 20, (Audit No. EMA-56) 2022 US Fuel Internal Audit Report, Environmental, Health, Safety January 26,

& Licensing (June through December 2021) 2022 E05-18-202103 Second Quarter 2021 Data Reviewed; Physical Observation July 7, 2021 HP-7 of Stacks Environmental Audit E06-09-14 2021 Annual Groundwater Report June and 31

Inspection Type Designation Description or Title Revision or Procedure Date September 2021 Work Orders 13489036-FM02 Maintenance Order - IG000027-0002- Flow Meter- South December Fenceline Sampler 17, 2020 13521583 Maintenance Order - Systematic Maintenance Flowmeter - August 29, East Fenceline Sampler 2021 88051 Miscellaneous 2022 PERMT/PERT Field Exercise 04/27/2022 Framatome Inc., 2022 Field Exercise Scenario and Objectives 02/25/2022 Richland Facility Emergency

Response

Organization Procedures E08-01-1.0 Emergency Plan Version 16.0 E08-03-1.1 Classifying an Emergency Version 7.0 E08-03-2.1 Emergency Preparedness - Part III Determining Protective Version 4.0 Actions E08-03-3.1 Plant Emergency Director Version 10.0 E08-03-3.4 Accountability Liaison Version 10.0 E08-03-3.5 PERT Liaison Version 6.0 E08-03-3.7 Staging Area Supervisor Version 9.0 E08-03-3.8 PERT Incident Commander Version 8.0 E08-03-4.1 Incident Notification Form Version 7.1 E08-03-4.2 Incident Notification Worksheet Version 18.0 E08-03-4.4 Incident Notification Worksheet - PERMT Version 6.0 E08-03-6.2 Chemical Field Team Procedure Version 7.0 E08-03-6.3 Personnel Monitoring Version 4.0 E08-03-6.5 Chemical Spill Response Plan Version 8.0 E08-03-8.2 Plant Evacuation Procedures - Offsite Version 7.0 E08-03-8.3 Plant Evacuation Procedures - Onsite Version 4.0 E08-03-8.4 Plant Evacuation Procedures - Individuals Buildings Version 4.0 E08-03-8.7 Emergency Action Guides Version 4.0 32

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