ML22213A046

Nuclear Fuel Services, Inc. - Core Inspection Report 07000143/2022002 and Notice of Violations

ML22213A046
Person / Time
Site:	Erwin
Issue date:	08/02/2022
From:	Robert Williams NRC/RGN-II/DFFI/FFB1
To:	Dailey R Nuclear Fuel Services
References
IR 2022002
Download: ML22213A046 (26)

Text

AUGUST 1, 2022 Mr. Ronald Dailey President Nuclear Fuel Services, Inc.

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

SUBJECT:

NUCLEAR FUEL SERVICES, INC. - CORE INSPECTION REPORT 07000143/2022002 AND NOTICE OF VIOLATIONS

Dear Mr. Dailey:

On June 30, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Nuclear Fuel Services, Inc. On July 13, 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 (Enclosure 2).

The enclosed report discusses two Severity Level IV violations. The NRC evaluated these violations in accordance Section 2.3.2 of the NRC Enforcement Policy, which can be found at http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. We determined that these violations did not meet the criteria to be treated as non-cited violations because the licensee did not identify the violations. The NRC has determined that the reason, corrective actions taken and planned to address recurrence, and the date when full compliance was achieved for these violations is adequately addressed and captured on the docket in the enclosed inspection report. Therefore, you are not required to respond to this letter unless the record does not accurately reflect your corrective actions or your position. In that case, or if you choose to provide additional information, you should follow the instructions specified in the enclosed Notice (Enclosure 1).

If you contest the violations or the significance or severity of the violations documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement; and the NRC Resident Inspector at Nuclear Fuel Services, Inc.

R. Dailey 2 This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Signed by Williams, Robert on 08/01/22 Robert E. Williams, Jr., Chief Projects Branch 1 Division of Fuel Facility Inspection Docket No. 07000143 License No. SNM-124

Enclosures:

- Notice of Violations - Nuclear Fuel Services, Inc -

Inspection Report 07000143/2022002 cc w/ encl: Distribution via LISTSERV

ML22213A046 SUNSI Review Non-Sensitive Publicly Available Sensitive Non-Publicly Available OFFICE RII/DFFI RII/DFFI RII/DFFI RII/DFFI RII/DFFI NMSS RII/DFFI NAME L. Harris J. Rivera L. Cooke T. Sippel P. Startz J. Munson R. Williams DATE 7/26/2022 7/25/2022 7/25/2022 7/25/2022 7/26/2022 7/26/2022 8/1/2022 NOTICE OF VIOLATIONS Nuclear Fuel Services, Inc. Docket No.: 07000143 07000143 - Nuclear Fuel Services, Inc. License No.: SNM-124 Consistent with the NRC Enforcement Policy and Title 10 of the Code of Federal Regulations (CFR) Part 2.201, the following violations identified in inspection report 2022002 are being cited:

(1) Materials License SNM-124, Amendment 16, Safety Condition S-1, states that the licensee shall conduct activities in accordance with the statements, representations, and conditions in the license application.

License Application, Section 11.4, Procedure Development and Implementation, states in part that activities involving the handling of special nuclear material (SNM) are conducted in accordance with written procedures as defined in this section. This section also states, in part, that operating procedures are documents written to authorize the processing of radioactive material; and, within these documents, detailed instructions for operation of equipment used in the process or activity, instructions for disposition of radioactive wastes, and limits and controls established for safety purposes are identified.

Standard Operating Procedure SOP-401-17, "FMF Cleaning (U)," Revision 10, includes several chemical safety instructions to ensure incompatible chemicals are segregated to prevent fires involving SNM. Specifically, SOP-401-17 states, in part:

WARNING: A chemical reaction OR fire may occur if oxidizers, flammable liquids, AND nitric acid spills are not segregated from combustibles (i.e., paper or cheesecloth).

Ensure to segregate incompatible materials (i.e., nitric acid AND organic) in waste containers.

If cheesecloth gets in contact with an oxidizer (i.e., nitric acid or hydrogen peroxide), then rinse and wipe thoroughly with water." Then, dry cheesecloth until damp, and ensure no more free liquid can be squeezed out to prevent a chemical reaction or fire.

If combustibles contact oxidizers (e.g., nitric acid), then wash and air-dry combustible material to prevent fire.

Contrary to the above, on January 25, 2022, the licensee failed to follow the chemical safety instructions in procedure SOP-401-17 to segregate cleaning materials (i.e.,

cheesecloth) that had been in contact with an incompatible chemical (i.e., nitric acid),

resulting in a small fire involving NRC-licensed material.

This violation is identified as VIO 70-143/2022002-01, Failure to Follow Procedure Requirements for Inventory Cleanout Activities in Building 302 (Event Notification 55712/Written Event Report 2022-001-00) and is considered closed based on the inspection activities documented in NRC Inspection Report 07000143/2022002.

Enclosure 1

(2) 10 CFR 70.24 (a) states, in part, that each licensee authorized to possess SNM in the quantities specified in that paragraph shall maintain in each area in which such licensed SNM is handled, used, or stored, a monitoring system which will energize clearly audible alarm signals if accidental criticality occurs.

Contrary to this requirement, from May 13 through 18, 2022, the licensee failed to maintain a monitoring system capable of energizing clearly audible alarm signals in certain areas of the facility in which licensed SNM is handled, used, or stored if an accidental criticality had occurred in any area of the facility monitored by the CAAS. Specifically, an announcement for a non-nuclear event revealed that the CAAS and fire protection systems were unable to provide annunciation coverage in certain peripheral buildings where SNM is handled due to a mispositioned switch that disabled the signal amplification function to the speakers in those areas for approximately five days.

This violation is identified as VIO 70-143/2022002-02, Failure of Criticality Accident Alarm System Speakers (Event Notification 55902/Written Event Report 2022-002-00).

and is considered closed based on the inspection activities documented in NRC Inspection Report 07000143/2022002.

These violations are associated with Severity Level IV findings.

Replying to Notice of Violation The NRC has concluded that information regarding the reason for the violations, the corrective actions taken and planned to correct the violation and the date when full compliance was achieved is already adequately addressed on the docket in Inspection Report No.

07000143/2022002 dated August 1, 2022. However, you are required to submit a written statement or explanation under 10 CFR 2.201 if the description on the docket does not accurately reflect your corrective actions or your position. In that case, or if you choose to respond, please mark your reply Reply to a Notice of Violation; and send it to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001 with a copy to the Regional Administrator, Region 2, and a copy to the NRC Resident Inspector at 07000143 - Nuclear Fuel Services, Inc., within 30 days of the date of the issuance of this Notice of Violation.

If you choose to respond, your response 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 consistent with 10 CFR 2.390. Therefore, to the extent possible, the response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the Public without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.390(b) to support a request for withholding confidential commercial or financial information).

Dated August 1, 2022 2

U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number: 07000143 License Number: SNM-124 Report Number: 07000143/2022002 Enterprise Identifier: I-2022-002-0064 Licensee: Nuclear Fuel Services, Inc.

Facility: Nuclear Fuel Services, Inc.

Location: Erwin, TN Inspection Dates: April 01, 2022 to June 30, 2022 Inspectors: L. Cooke, Fuel Facility Inspector L. Harris, Senior Resident Inspector J. Munson, Senior Nuclear Process Engineer J. Rivera Ortiz, Sr. Fuel Facility Project Inspector T. Sippel, Fuel Facility Inspector P. Startz, Fuel Facilities Inspector Approved By: Robert E. Williams, Jr., Chief Projects Branch 1 Division of Fuel Facility Inspection Enclosure 2

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a core inspection at Nuclear Fuel Services, Inc, in accordance with the fuel cycle facility inspection program. This is the NRCs program for overseeing the safe operation of licensed fuel cycle facilities. Refer to https://www.nrc.gov/materials/fuel-cycle-fac.html for more information.

List of Violations Failure to Follow Procedure Requirements for Inventory Cleanout Activities in Building 302 (EN 55712/WER 2022-001-00)

Significance Report Section Severity Level IV 88135.02 NOV 07000143/2022002-01 Closed The inspectors identified a self-revealing, Severity Level IV, cited violation of License Condition S-1 for the failure to follow standard operating procedures during material inventory cleanout activities in Building 302.

Failure of Criticality Accident Alarm System Speakers (EN 55902/WER 2022-002-00)

Significance Report Section Severity Level IV 88135.02 NOV 07000143/2022002-02 Closed The inspectors identified a self-revealing, Severity Level IV, cited violation of 10 CFR 70.24 due to the failure of the CAAS to generate clearly audible alarm signals for a period greater than eight hours.

Additional Tracking Items Type Issue Number Title Report Section Status URI 07000143/2022001-01 Application of Setpoint 88020 Closed Methodology for Item Relied on for Safety WER 07000143/2022-001-00 Unplanned Chemical 88135.02 Closed Reaction/Fire (EN 55712)

WER 07000143/2022-002-00 Criticality Accident Alarm 88135.02 Closed System Speakers Disabled (EN 55902) 2

PLANT STATUS The following facility process areas were operating during the inspection period: 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 10 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 evaluations (NCSEs), and associated assumptions and calculations, to verify compliance with 10 CFR 70 and applicable sections of the license application, including 5.1.1 and 5.5.1. Specifically, the inspectors interviewed licensee staff and reviewed portions of the following NCSEs:

54X-08-0004, "Nuclear Criticality Safety Evaluation for Area 700 of the Production Fuel Facility," Rev. 4, including the review of what-if analyses and calculations for selected credible accident sequences 54X-08-0005, "Control Flowdown and Field Verification for Area 800," Rev. 3, which documented the licensee's verification of items relied on for safety (IROFS) in Area 700 54X-18-0001, "Nuclear Criticality Safety Evaluation for Area 300/400 of the Production Fuel Facility," Rev. 2, including the review of the what-if analysis, credible accident sequences, such as backflow, and non-credible accident sequences 54X-22-0002, "Control Flowdown and Field Verification for Area 300/400 of the Production Fuel Facility," dated 01/31/2022, documented the licensee's verification of the IROFS in Area 400 3

54X-22-0003, "Nuclear Criticality Safety Evaluation for Area 800 of the Production Fuel Facility," Rev. 13, including the review of what-if analyses and calculations for selected credible accident sequences 54X-22-0004, "Control Flowdown and Field Verification for Area 800," Rev. 0, which documented the licensee's verification of the IROFS in Area 800 Criticality Implementation (IP Section 02.02)

The inspectors selected a sample of engineered and administrative controls from the licensees integrated safety analysis (ISA) summary to verify proper implementation through a review of process and control specifications, plant walkdowns, and operator interviews, and to verify compliance with 10 CFR 70 and applicable sections of the license application, including 5.3.2, 5.3.7 and 11.2.3. Specifically, the inspectors interviewed licensee staff and performed the activities listed below:

reviewed preventive maintenance records and procedures for IROFS 300-01,

-02, -04, and -05 reviewed overflow drain IROFS 300-01, and 300-02; including setpoint analysis SA-00001 reviewed overflow drain IROFS 300-04, and 300-05; including setpoint analysis SA-00324 reviewed various NCS Postings reviewed portions of 27X-21-0006, NFS Training Department Lesson Plan, Slides, and Handouts for OT-302COMMON, which provides NCS training to operators in Building 302 conducted walkdowns in Area 400 using drawings 302-F0116-D Sheet 1, "Area 400 P&ID," and 302-F1157-D, Sheet 8, "Area 400/500 Piping and Instrumentation Diagram" conducted walkdowns in Areas 700 and 800 to verify the presence of safety controls 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, including 5.3.2, 5.3.4, 11.3.1 and 11.5. Specifically, the inspectors performed the following activities:

reviewed reports of NCS audits conducted in 2022, and interviewed NCS engineers concerning the conduct of and training for NCS audits, and findings and observations identified during the audits interviewed Area 400 operators concerning criticality hazards and control methods reviewed NCS training provided to operators, including 27T-20-2094, "General Employee Training;" and 27T-21-1626, "2022 Annual Safety Refresher Training" observed a licensee NCS engineer conduct a weekly audit in BPF 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 2.3.5.1 and 5.3.3. Specifically, the inspectors performed the following:

interviewed licensee staff and reviewed NCS engineer's qualification to support emergency response reviewed NCS engineer qualification record reviewed the most recent revision of licensee procedure NFS-HA-A-68, "ISA Risk Assessment Procedure" Criticality Incident Response and Corrective Action (IP Section 02.05)

The inspectors reviewed the licensees criticality accident alarm system (CAAS) and corrective action program entries to verify compliance with 10 CFR 70 and applicable sections of the license application, including 5.3.9. Specifically, the inspectors performed the following:

reviewed a sample of recent NCS-related entries in the problem identification, resolution, and corrective system (PIRCS), and associated event investigations and corrective actions, including those identified by NCS engineers during audits reviewed NFS-HS-E-02, "Emergency Criticality Evacuation," Rev. 49; Drawing 000-C0002-B, "Emergency Evacuation Routes;" and various NCS evacuation drill records for calendar years 2020 and 2021 walked down portions of the CAAS, reviewed PIRCS entry 88234, interviewed licensee staff, and observed audibility testing performed in response to the CAAS speaker failure reported to the NRC via Event Notification55902 (See "Inspection Results" section of this report for additional details) 88020 - Operational Safety Implementation of Safety Controls (IP Section 02.03)

NRC Inspection Report 07000143/2022001 (ADAMS Accession Number ML22122A196) documented unresolved item (URI) 07000143/2022001-01 related to engineering calculation SA-00048, "BSX-012, BSX-016 Evaporator Steam Pressure Setpoint Analysis," Revision 8, which established the setpoint for pressure transmitter PIT-2017. This pressure transmitter supports the function of IROFS BSX-12 to reduce the likelihood of a red oil explosion in the BPF solvent extraction process. This IROFS is credited in the ISA Summary for shutting down a set of electrical heaters in the BPF solvent extraction process when the steam pressure reaches a specific value. The inspectors opened the URI because additional information was needed to determine whether the setpoint calculation properly accounted for tolerances, safety margin, and response times as required by License Condition S-

3. The inspectors further interviewed licensee staff and reviewed instrument diagrams, setpoint calculations, engineering procedures, surveillance testing records, and manufacturers' data information associated with the instrument loop that controls the function of IROFS BSX-12.

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The inspectors' review resulted in a minor violation of License Condition S-3. See "Inspection Results" section of this report for details.

88135.02 - Plant Status The inspectors routinely conducted walkdowns of licensee areas, observed operators, material control and accounting (MC&A) 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 that licensed activities were conducted safely and in compliance with the license and 10 CFR 70, Domestic Licensing of Special Nuclear Material.

Status Meetings (IP Section 03.02)

The inspectors, on a routine basis, attended and reviewed the results of scheduled licensee meetings to determine plant status and become aware of site activities so that inspection resources were appropriately focused on those activities with the higher safety significance.

The inspectors selected the following meetings for review:

Safety and Safeguards Review Council Corrective Action Review Board Nuclear Safety Review Board Record and Log Reviews (IP Section 03.03)

The inspectors reviewed selected records and logs to ensure they were developed, maintained, and reported, as required by applicable license and regulatory requirements.

Identification and Resolution of Problems (IP Section 03.05)

The inspectors reviewed selected issues to determine if the licensee was entering equipment, human performance, and other performance issues in a formalized program to identify, track and assure correction of safety and safeguard significant problems, in accordance with 10 CFR 70.62(a)(3) and applicable license requirements. The issues selected for review are listed in the "Documents Reviewed" section of this report as PIRCS.

Event Review (IP Section 03.06)

The inspectors reviewed the plant events listed below to determine if the events warranted the use of formal event review criteria. As applicable, the inspectors reviewed the events to determine whether the licensee reported the issue in accordance with 10 CFR Parts 40.60 (source material), 70.50 (mainly radiological events), 70.52 (criticality and safeguards events), 71.95 (transportation events), 73.71 (safeguards events), and 20.22 (radiological and environmental events). The inspectors also reviewed the licensees response, safety consequences, and corrective actions for the listed events.

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EN 55712, Unplanned Chemical Reaction/Fire (WER 07000143/2022-001-00), dated January 25, 2022 (See "Inspection Results" section of this inspection report for additional details)

EN 55902, Criticality Accident Alarm System Speakers Disabled (WER 07000143/2022-002-00), dated May 19, 2022 (See "Inspection Results" section of this inspection report for additional details)

Audits (IP Section 03.07)

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

As Low As Reasonably Achievable (ALARA) Occupational Exposure Report for Calendar Year 2021, 4th Quarter MC&A Status Report Procedures (IP Section 03.08)

The inspectors reviewed selected procedures to determine if the licensee was using and maintaining them in accordance with applicable license requirements. The procedures selected for review are listed in the "Documents Reviewed" section of this report.

Radiation Work Permit (RWP) (IP Section 03.09)

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

SWP 18165 303-600 SWP 22-34-004 333 Annual Security and Emergency Preparedness Drills/Exercises (IP Section 03.10)

The inspectors observed the licensees performance during the Emergency Preparedness activity listed below to determine if it was implemented in accordance with 10 CFR 70.22(I)(3).

On April 26, 2022, the inspectors observed an emergency training drill simulating a fire within the protected area. The drill exercised activation of the Emergency Control Center (ECC), fire scenario response, event classification, and notification to off-site organizations.

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 7

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.

Operations Safety Walkdown (IP Section 03.01)

The inspectors evaluated the safety controls/IROFS listed below associated with processing Areas 300, 400, and 500.

N302XOVRFL0403A N302XDRAINH0401 N302XMVXXXXA301 N302XXXXPDAA316 N302OVRFLOA305 FA5-003 FA5-004 N302XXXXLSH0544 FA5-021 FIRE3-1 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 National Fire Protection Association (NFPA) 801, Standard for Fire Protection for Facilities Handling Radioactive Materials, as applicable. Also, the inspectors evaluated on-site fire brigade training and drill performance to verify compliance with Chapter 7, Fire Safety of the license application.

Fire Area Walkdown (IP Section 03.01)

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

Area 800 and the following associated activities: monthly combustible control inspections, fire hazard analysis; and fire safety tests N306H2DIlXXX800, N306H2DETCTR800, and N306XFRDAMP001 Observation of preparation for and conduct of CO2 system test:

N302XXCO2SYSTEM Fire Brigade Drill Performance Sample (IP Section 03.02)

The inspectors evaluated the fire brigade training/drill performance described below:

On June 2, 2022, the inspectors observed classroom and practical training sessions, including the use of self-contained breathing apparatus (SCBA),

conduct of search and rescue operations, and attendance of training associated with a live-fire exercise.

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88135.19 - Post Maintenance Testing The inspectors evaluated post-maintenance test activities to verify compliance with license application Chapter 11, Management Measures, and test procedures and/or work instructions to confirm functional capability of selected IROFS and/or safety control(s) following maintenance.

Post-Maintenance Testing (IP Section 03.01)

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

N306VALVETWA874 N302VENDRAIN001 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 verify compliance with license application Chapter 11, Management Measures, and the performance requirements of 10 CFR 70.61 and 70.62; and to verify the IROFS maintained their operational readiness consistent with the ISA.

Surveillance and Calibration Testing (IP Section 03.01)

The inspectors reviewed the four surveillance tests listed below. Tests were either observed directly or test results were reviewed.

N302XSSTRANR0543 N302XXXXLSH0544 X304FILTERVK01 N302VENTPSV0668 FACILITY SUPPORT 88051 - Evaluation of Exercises and Drills The inspectors observed and evaluated the licensees graded biennial exercise conducted on June 14, 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 included a simulated large fire at the Wastewater Treatment Facility that resulted in simulated spills and injuries to several individuals.

Exercise Planning (IP Section 02.01)

The inspectors reviewed the emergency exercise scenario, discussed the exercise objectives with licensee personnel, observed briefings, 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 reviewed the following:

the frequency of exercises conducted by the licensee 9

the scenario as it related to testing applicable elements of the Emergency Plan pre-staging of equipment in preparation for the exercise duties and responsibilities for exercise personnel including controllers, simulators, evaluators, and observers confidentiality of the scenario and objectives Exercise Execution and Emergency Plan Implementation (IP Section 02.02)

The inspectors observed the execution of the exercise at different response locations on-site. The inspectors observed the initiation of the emergency exercise, the activation of the Emergency Response Organization (ERO) and execution of ERO functions at the ECC, the on-scene command post, and at the scene of the simulated emergency to verify compliance with the Emergency Plan, Emergency Plan Implementing Procedures, and 10 CFR 70.22(i)(3)(xii). The inspectors reviewed the following:

staffing for all ERO positions at the ECC and on-scene command post, including the on-site fire brigade the licensees analysis of plant conditions including assessment and classification of the accident scenario Emergency Control Director (ECD) and On-scene Coordinator (OSC) command and control of the emergency dose assessment activities during the exercise scenario and the use of applicable dose assessment tools for occupational and public consequences environmental monitoring and dose assessment calculations evaluation of protective action recommendations by ECC staff, as applicable to the exercise on-site communication to occupational workers as it related to plant conditions and protective action recommendations press releases and off-site notifications to local, state, and federal government entities on-scene emergency response teams actions including search and rescue activities for casualties, fire mitigation, and control of chemical/radiological releases the OSC and Fire Brigade Chief command and control of the emergency response team and coordination of actions with off-site emergency responders occupational workers participation in protective actions and accountability activities, as applicable to the exercise scenario recovery and re-entry recommendations implemented by the ECD controllers' interactions with exercise participants to determine whether controller's actions were consistent with exercise objectives response coordinators recommendations regarding conditions for terminating the event and restarting normal operations response and management of unplanned situations during the exercise 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 10

Plan, Emergency Plan Implementing Procedures, and 10 CFR 70.22(i)(3)(xii). The inspectors reviewed the following:

critiques conducted by the licensee with the controller staff and ECC participants critique conducted by the licensee with the controller staff and on-scene participants documented deficiencies identified during critiques including items planned for entry into the licensees corrective action program INSPECTION RESULTS Minor Violation 88020 Minor Violation: The inspectors' review of URI 07000143/2022001-01 resulted in a minor violation of Safety Condition S-3 for the failure to account for the response time of various contact relays in the control circuit of IROFS BSX-12.

NRC Materials License SNM-124, Amendment 16, Safety Condition S-3, states in part that NFS shall utilize, for setpoint determinations, conservative engineering analyses which account for safety limits, instrument and system accuracies, response times, instrument drift, manufacturers' data and operating experience. Contrary to this requirement, engineering setpoint calculation SA-00048, Revision 8, did not account for the response time and manufacturers' data of four contact relays (CR-710801, CR-710802, CR-3265485A, and CR-3265485B) and two motor contactors (CR-3265485A and CR-3265485B) in the control circuit for IROFS BSX-12. The failure to account for the response time affected the trip setpoint calculation for the pressure transmitter (PIT-2017) that supports the function of IROFS BSX-12.

Screening: The inspectors determined the violation was minor. The violation was minor in significance consistent with IMC-0616, Fuel Cycle Safety and Safeguards Inspection Reports, Appendix B, Examples of Minor Violations, Example 1b, because the safety function of IROFS BSX-12 was maintained and performance requirements were still met with adequate safety margin due to the additional IROFS in place to reduce the likelihood of a red oil explosion event. The licensee entered this issue in the corrective action program as PIRCS 87990.

Enforcement: This failure to comply with Safety Condition S-3 constitutes a minor violation that is not subject to enforcement action in accordance with the NRC Enforcement Policy. This URI is considered closed.

Failure to Follow Procedure Requirements for Inventory Cleanout Activities in Building 302 (EN 55712/WER 2022-001-00)

Severity Report Section Severity Level IV 88135.02 NOV 07000143/2022002-01 Closed The inspectors identified a self-revealing, Severity Level IV, cited violation of License Condition S-1 for the failure to follow standard operating procedures during material inventory cleanout activities in Building 302.

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Description:==

On January 25, 2022, a chemical reaction occurred in a two-liter container during material inventory cleanout activities in Building 302. The container was inside a process enclosure at the time plant operators observed the first indications of a chemical reaction and smoldering, which eventually progressed to a small fire. The container was damaged in the fire, releasing its contents to the enclosure. The contents of the two-liter container were a combination of cleanup material waste commingled with highly enriched uranium. The NFS's Fire Brigade responded promptly and extinguished the fire inside the enclosure. The licensee did not identify equipment damage outside of the process enclosure. Additionally, the licensee did not identify any personnel injuries, exposures, contamination, or releases to the environment exceeding regulatory limits. The licensee reported the event within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> under the provisions of 10 CFR 70.50 (ADAMS Accession Number ML22066B008).

The cause of the fire was attributed to chemical incompatibility of the materials placed in the two-liter container by plant operators. Per NFS's standard operating procedure (SOP) 401-17, "FMF Cleaning," inventory cleanout of equipment in the affected process area may consist of sequential rinses with caustic solution, acid solution, and deionized water. Cheesecloth rags are typically used for wiping down surfaces during these cleanout rinses. Per SOP-401-17, cheesecloth rags that have been in contact with nitric acid are supposed to be thoroughly rinsed with water after use and dried before being placed in waste containers to avoid introduction of incompatible materials in the same container.

The licensee's cause investigation determined that on January 20, 2022, operators completed nitric acid rinses of some components in the subject process enclosure as planned. Operators observed that some of the acid solution overflowed and spilled on the bottom of the enclosure, which is not considered an abnormal occurrence during cleanout activities. From January 20 through 25, 2022, additional operators performed water rinses of the same components as scheduled and used cheesecloth rags to clean up the enclosure floor. However, the operators did not rinse the cheesecloth rags with water prior to placing them in the container under the wrong assumption that the solution being handled was just water.

The most probable cause of the chemical reaction was that residual nitric acid solution from previous rinses was still present on the enclosure floor and the operators who performed the water rinses did not realize they were also collecting nitric acidic solution in the cheesecloth. By assuming the solution was only water and not following the chemical safety measures in SOP-401-17, the operators ended up placing incompatible materials (i.e., nitric acid, cheesecloth, plus other materials) in the same container. The nitric acid reacted with the organic materials in the container resulting in an exothermic reaction and eventually the fire.

Corrective Actions: Immediate corrective actions for the event included personnel evacuation from the process area, fire brigade response, placing affected processes in safe shutdown, damage assessment, personnel access restrictions, suspension of hot work in the area, chemical and radiological sampling of process area and process ventilation, medical evaluation of personnel involved in the event, and extent of condition review for similar plastic containers.

The licensee also conducted a root cause evaluation and identified the following corrective actions (CAs) to prevent reoccurrence:

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CA 41130 - Create a plant-wide chemical safety policy to clearly communicate management expectations for chemical safety CA 41136 - Revise SOP 401-17 to enhance guidance on handling chemically-tainted materials CA 41131 - Revise SOP 401-15B-302 to specifically cover cleaning of the enclosure floor and rinsing all combustible cleaning material CAs 41133 through 41135 - Revise SOPs to cover instructions for rinsing and drying combustible cleaning materials that have been used for wiping down enclosures CAs 41137 through 41140 - Revise SOPs to cover instructions for rinsing and drying combustible cleaning materials that have been in contact with oxidizers Conduct training for operators on procedure revisions Corrective Action

References:

The licensee entered this issue into its corrective action program as PIRCS 87147.

Analysis: The inspectors determined the failure to follow the chemical safety instructions in SOP-401-17 constituted a violation of License Condition S-1 for not handling SNM in accordance with written procedures as defined in Section 11.4 of the license application. The violation was determined to be self-revealing because it became apparent as a result of a plant event. The inspectors determined the violation was more-than-minor based on the screening criteria in IMC 0616, Appendix B. The inspectors determined the violation could reasonably be considered a precursor to a significant event per Question 1 of the screening process because it was similar to Example 1a, in that the failure to follow a procedure resulted in an unsafe configuration of SNM that adversely impacted nuclear or radiological safety of equipment and personnel. Specifically, the failure to follow a procedure resulted in a small fire that adversely impacted the containment of SNM.

The inspectors interviewed licensee staff and independently reviewed documentation for the determination of actual and potential consequences. This event did not result in serious safety consequences because: (1) operators recognized the chemical reaction and fire brigade responded promptly; (2) the fire occurred inside a process enclosure, which prevented any potential occupational exposure and environmental release from exceeding regulatory limits; (3) the fire did not involve amounts of SNM that could result in an event of intermediate or high consequences as defined in 10 CFR 70.61 and the approved ISA methodology for the facility; (4) the affected process was in inventory shutdown mode in which normal amounts of SNM and combustible materials are removed to support inventory cleanout; (5) the area's air sample monitors did not detect activity requiring further action; and (6) the post-event contamination of employees did not result in employee injuries or radiological/chemical exposure beyond NRC regulatory limits.

The inspectors determined the violation was of Severity Level IV significance because it aligned with Example 6.2.d.2 of the Enforcement Policy in that the violation involved the failure to maintain chemical safety controls to prevent fire but the failure did not result in a Severity Level I, II, or III violation. Additionally, in accordance with Section 2.2.2 of the NRC Enforcement Policy, violations that are less serious but are of more-than-minor concern and result in no or relatively inappreciable potential safety consequences are characterized as Severity Level IV violations.

Enforcement:

Severity: This is a Severity Level IV violation consistent with Example 6.2.d.2 of the NRC Enforcement Policy.

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Violation: Materials License SNM-124, Amendment 16, Safety Condition S-1, states that the licensee shall conduct activities in accordance with the statements, representations, and conditions in the license application.

License Application, Section 11.4, Procedure Development and Implementation, states in part that activities involving the handling of SNM are conducted in accordance with written procedures as defined in this section. This section also states, in part, that operating procedures are documents written to authorize the processing of radioactive material; and, within these documents, detailed instructions for operation of equipment used in the process or activity, instructions for disposition of radioactive wastes, and limits and controls established for safety purposes are identified.

Standard Operating Procedure SOP-401-17, "FMF Cleaning (U)," Revision 10, includes several chemical safety instructions to ensure incompatible chemicals are segregated to prevent fires involving SNM. Specifically, SOP-401-17 states, in part:

WARNING: A chemical reaction OR fire may occur if oxidizers, flammable liquids, AND nitric acid spills are not segregated from combustibles (i.e., paper or cheesecloth).

Ensure to segregate incompatible materials (i.e., nitric acid AND organic) in waste containers.

If cheesecloth gets in contact with an oxidizer (i.e., nitric acid or hydrogen peroxide),

then rinse and wipe thoroughly with water." Then, dry cheesecloth until damp, and ensure no more free liquid can be squeezed out to prevent a chemical reaction or fire.

If combustibles contact oxidizers (e.g., nitric acid), then wash and air-dry combustible material to prevent fire.

Contrary to the above, on January 25, 2022, the licensee failed to follow the chemical safety instructions in procedure SOP-401-17 to segregate cleaning materials (i.e., cheesecloth) that had been in contact with an incompatible chemical (i.e., nitric acid), resulting in a small fire involving NRC-licensed material.

This violation is identified as VIO 70-143/2022002-01, Failure to Follow Procedure Requirements for Inventory Cleanout Activities in Building 302 (EN 55712/WER 2022-001-

00) and is considered closed based on the inspection activities documented under IP 88135.02, Section 03.06, of this inspection report.

Enforcement Action: This violation is being cited because the licensee does not have an NRC-approved Corrective Action Program and did not identify the violation, consistent with Section 2.3.2 of the Enforcement Policy.

Failure of Criticality Accident Alarm System Speakers (EN 55902/WER 2022-002-00)

Severity Report Section Severity Level IV 88135.02 NOV 07000143/2022002-02 Closed 14

The inspectors identified a self-revealing, Severity Level IV, cited violation of 10 CFR 70.24 due to the failure of the CAAS to generate clearly audible alarm signals for a period greater than eight hours.

==

Description:==

On May 18, 2022, the licensee made a plant announcement to activate the fire brigade personnel in response to a non-nuclear event in a licensee's building outside the protected area. At the time of the announcement, the licensee was conducting a scheduled surveillance involving the alarm panel for the fire protection system and the CAAS. However, the licensee noticed that certain areas on the periphery of the site had trouble hearing the fire brigade activation announcement. Upon following up, the licensee found that a switch controlling the amplifiers for the CAAS speakers in the affected areas was in the off position. The licensee tested the CAAS and fire alarms to determine if they were audible while the amplifiers switch was turned off. The test confirmed the CAAS and fire alarm system would not have been able to produce clearly audible alarm signals in some plant areas if an accidental criticality, fire alarm, or another fire announcement had occurred. The licensee restored the system on May 18 at approximately 15:00 (EDT).

The lack of annunciation coverage for fire and criticality safety alarms was limited to certain peripheral buildings where SNM is handled. The buildings housing the main fuel processes and laboratories remained covered by redundant annunciation from a newly installed CAAS system. Additionally, fire strobes in the affected buildings remained available to provide visual notification of fire alarms. The licensee determined the CAAS and fire protection systems were unable to produce clearly audible signals in the affected areas for up to five days based on the last audibility test of the speaker system, which was performed on May 13, 2022 at approximately 1100 hours0.0127 days <br />0.306 hours <br />0.00182 weeks <br />4.1855e-4 months <br /> (ET). The licensee's investigation also determined that on May 17, 2022, the licensee performed a preventive maintenance (PM) activity to record weekly fire trouble alarm logs. Plant staff in charge of the PM recorded a trouble alarm that indicated potential issues with the affected speaker amplifier, but these were not recognized by licensee's fire protection staff prior to discovering the amplifier's switch in the "off" position.

The licensee reported this issue to the NRC on May 19, 2022, under the provisions of 10 CFR 70.50(b)(2) and submitted a written follow-up report on June 16 (ADAMS Accession Number ML22178A025).

Corrective Actions: Licensee immediate corrective actions for this event included: (a) upon discovery, the licensee tested and restored the system promptly, (b) since the time of discovery, licensee staff monitored the CAAS and fire alarm panel as a compensatory measure, and (c) the licensee entered the issue in the corrective action program for investigation.

After further evaluation, the licensee revised the procedure and form used to complete CAAS switch alignments to ensure adequate configuration of the switches is maintained during future surveillance and maintenance activities. The licensee's procedure was also revised to address use of human performance tools to prevent errors in operating the system. The licensee generated a training toolbox to institute the changes to the procedure and form, as well as reinforce the importance of switch alignment. Longer term actions scheduled to be completed included modifying the switch position indicators and displays, as well as improving the arrangements of components, and modifying lesson plans to incorporate the lessons learned specific to this event.

Corrective Action

References:

The licensee entered this issue into its corrective action program as PIRCS 88397 and 88234.

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Analysis: The inspectors determined the failure of the CAAS to generate clearly audible signals in the affected areas was a violation of 10 CFR 70.24. The inspectors considered the violation to be self-revealing because the licensee staff responsible for reviewing the fire trouble alarms log did not recognize the trouble alarm indicating potential issues with the speakers. Additionally, the lack of annunciation coverage became apparent as a result of an actual plant announcement for a non-nuclear emergency outside the protected area. The violation was determined to be of more-than-minor significance consistent with Question 10 and Example 2k in IMC-0616, Appendix B, because the system was unable to provide annunciation coverage for a period greater than eight hours without compensatory measures being in effect. Had a criticality accident or further fire announcements occurred, people in the affected buildings would not have been able to receive clear audible indications as personnel in process areas covered by the redundant CAAS speakers. This could have delayed evacuation and accountability actions for individuals in the affected buildings. The inspectors determined the violation was of Severity Level IV significance consistent with Example 6.2.d.5 of the NRC Enforcement Policy, specifically because the CAAS failed to provide annunciation coverage of fissile material operations during a time period when fissile material was handled, used, or stored; and the failure did not exist for a substantial time period. This violation did not result in actual radiological consequences.

Enforcement:

Severity: This is a Severity Level IV violation consistent with Example 6.2.d.5 of the NRC Enforcement Policy.

Violation: 10 CFR 70.24 (a) states, in part, that each licensee authorized to possess SNM in the quantities specified in that paragraph shall maintain in each area in which such licensed SNM is handled, used, or stored, a monitoring system which will energize clearly audible alarm signals if accidental criticality occurs.

Contrary to this requirement, from May 13 through 18, 2022, the licensee failed to maintain a monitoring system capable of energizing clearly audible alarm signals in certain areas of the facility in which licensed SNM is handled, used, or stored if an accidental criticality had occurred in any area of the facility monitored by the CAAS. Specifically, an announcement for a non-nuclear event revealed that the CAAS and fire protection systems were unable to provide annunciation coverage in certain peripheral buildings where SNM is handled due to a mispositioned switch that disabled the signal amplification function to the speakers in those areas for approximately five days.

This violation is identified as VIO 70-143/2022002-02, Failure of Criticality Accident Alarm System Speakers (EN 55902/WER 2022-002-00) and is considered closed based on the inspection activities documented under IP 88135.02, Section 03.06, of this inspection report.

Enforcement Action: This violation is being cited because the licensee does not have an NRC-approved Corrective Action Program and did not identify the violation, consistent with Section 2.3.2 of the Enforcement Policy.

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

On July 13, 2022, the inspectors presented the core inspection results to Mr. Ronald Dailey and other members of the licensee staff.

On May 20, 2022, the inspectors presented the nuclear criticality safety (IP 88015) inspection results to Mr. Michael McKinnon and other members of the licensee staff.

On June 14, 2022, the inspectors presented the biennial emergency exercise (IP 88051) inspection results to Mr. Steven Cowne and other members of the licensee staff.

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DOCUMENTS REVIEWED Inspection Type Designation Description or Title Revision or Procedure Date 88015 Calculations TJC-15-001 Rectangular Weir Calculations 05/01/2015 Corrective Action PIRCS: 86720, Various NCS related PIRCS entries, and associated Various Documents 86779, 86800, documents 87107, 87108, 87151, 87152, 87221, 87361, 87382, 87390, 87402, 87443, 87508, 87518, 87582, 87593, 87594, 87595, 87598, 87727, 87753, 87783, 87867, 87897, 88080 Drawings 000-C0002-B Emergency Evacuation Routes 12/11/2020 302-F0116-D Sheet Area 400 P&ID 06/27/2018 1

302-F0116-D Sheet Area 400 P&ID 08/20/2021 1

302-F1157-D Sheet Area 400/500 Piping and Instrumentation Diagram 06/12/2019 8

302-F1157-D Sheet Area 400/500 Piping and Instrumentation Diagram 01/19/2022 8

Engineering 54T-22-0003 Control Flowdown and Field Verification For Addendum 2 Rev. 0 Evaluations To The NCSE Waste Water Treatment Facility 54X-08-0004 Nuclear Criticality Safety Evaluation for Area 700 of the Rev. 4 Production Fuel Facility 54X-08-0005 Control Flowdown and Field Verification for Area 700 of Rev. 3 the Production Fuel Facility 54X-18-0001 Nuclear Criticality Safety Evaluation for Area 300/400 of Rev. 2 the Production Fuel Facility 54X-20-0003 Addendum 1 to Nuclear Criticality Safety Analysis Rev. 0 18

Inspection Type Designation Description or Title Revision or Procedure Date Transfer Carts and Process Floor Storage Rack 54X-22-0001 Control Flowdown and Field Verification For The NCSA Rev. 0 For Transfer Carts and Process Floor Storage Racks 54X-22-0002 Control Flowdown and Field Verification for Area 300/400 01/31/2022 of the Production Fuel Facility 54X-22-0003 Nuclear Criticality Safety Evaluation for Area 800 of the Rev. 13 Production Fuel Facility 54X-22-0004 Control Flowdown and Field Verification for Area 800 Rev. 0 54X-22-0006 Addendum 2 to the Nuclear Criticality Safety Evaluation Rev. 0 Waste Water Treatment Facility - Disposal of Unfiltered Nitrogen Analyzer Waste in the 105 Laboratory SA-00002 Setpoint Analysis for 300-001, 300-002 07/29/2019 SA-00324 Setpoint Analysis for 300-04, 300-05 08/27/2019 Miscellaneous Various 2020 Criticality Evacuation Drill Records Various 2021 Criticality Evacuation Drill Records 27T-20-2094 General Employee Training 08/19/2020 27T-21-1626 2022 Annual Safety Refresher Training 27X-21-0006 NFS Training Department Lesson Plan, Slides, and Handouts for OT-302COMMON N302XDRAINH0401 Inspection procedure, and record of 02/08/22 IROFS Rev. 2 Drain inspection N302XOVRFLO403A 02/27/2022 inspection record of IROFS overflow Rev. 2 N302XOVRFLO403B 02/27/2022 inspection record of IROFS overflow Rev. 2 Procedures Various NCS Postings (Station Limit Cards)

NFS-HS-A-68 ISA Risk Assessment Procedure Rev. 10 NFS-HS-E-02 Emergency Criticality Evacuation Rev. 49 Self- NCS-2022-01 Nuclear Criticality Safety Audit of the Nuclear Criticality 02/16/2022 Assessments Safety Evaluation for the CDL Liquid Waste Discard System NCS-2022-02 Nuclear Criticality Safety Audit of the SNM Processing 03/20/2022 Operations for Area 800 of the Production Fuel Facility NCS-2022-03 Nuclear Criticality Safety Audit of the Nuclear Criticality 03/21/2022 Safety Evaluation for Area E of the Uranium Recovery Facility 19

Inspection Type Designation Description or Title Revision or Procedure Date NCS-2022-04 Nuclear Criticality Safety Audit of the Nuclear Criticality 04/19/2022 Safety Evaluation for the Main Vault NCS-2022-05 Nuclear Criticality Safety Audit of the SNM Processing 04/25/2022 Operations for Tube Cleaning Room of the Production Fuel Facility NCS-2022-06 Nuclear Criticality Safety Audit of the SNM Processing 04/21/2022 Operations for the Check Weighing Areas 88020 Calculations SA-00048 BSX-012, BSX-016 Evaporator Pressure Setpoint Rev. 8 Analysis Drawings 333-I7108-B SRE Instrument Loop Diagram for Pressure Switch High 6/22/2021 PSH-2017 Engineering 21T-20-0673 Occupational/Environmental Chemical Accident Rev. 12 Evaluations Consequence Evaluation for BLEU Prep Facility Miscellaneous IROFS 333-USVXTR Safety Related Equipment Test Completed on 9/13/2021 Procedures ENG-EPS-A-003 Setpoint Verification and Design Parameter Calculations Rev. 14 88051 Corrective Action PIRCS 88607 Emergency Preparedness Critique 06/22/2022 Documents Fire Plans Pre-Fire Plan 44 Building 330 - Wastewater Treatment Facility (WWTF) 05/17/2019 Miscellaneous 2022 Biennial Emergency Preparedness Exercise 06/14/2022 NFS-GH-903 Emergency Plan Rev. 27 Procedures NFS-HS-E-03 Emergency Response Organization Rev. 37 NFS-HS-E-04 Fire Reporting and Response Rev. 41 NFS-HS-E-05 Spill Response and Reporting Rev. 41 NFS-HS-E-10 Emergency Communications Rev. 32 NFS-HS-E-15 Emergency Medical Response Rev. 20 88135.02 Calculations 21X-18-0043, NFE- Fire - Radiological Accident Consequence Evaluation Rev. 3 18-0364, HEA-21 LDT-22-002 ISA Evaluation of Events, PIRCS Problem ID 87147 2/2/2022 LDT-22-003 Update to ISA Evaluation of Events, PIRCS Problem ID 3/1/2022 87147 LDT-22-006 ISA Evaluation of Events, PIRCS Problem ID 87939 4/28/2022 LDT-22-007 Update to ISA Evaluation of Events, PIRCS Problem ID 5/12/2022 20

Inspection Type Designation Description or Title Revision or Procedure Date 87939 Corrective Action ACE000005 Accident Consequence Evaluation Rev. 7.0 Documents ACE000006 Attachment B-1 Rev. 11 PIRCS 87147 Fire in Building 302 1/25/2022 PIRCS 87873, Corrective Action Program Entries 87900, 88094, 88098, 88102, 88234, 88307, 88421, and 88424 Drawings 302-F0052-D Area D PI&D, Sheet 1 3/21/2022 Miscellaneous 21G-22-0023 30-Day written Notification of Event (NRC Event No. 2/22/2022 55712)

TCH-22-004 Call Notes and Information Requested 04/22/2022 Procedures NFS-HS-E-03 Emergency Response Organization Rev. 37 NFS-HS-E-04 Fire Reporting and Response Rev. 41 NFS-OPS-001 Conduct of Operations Rev. 14 & 16 OPR-TB-JAN22-05 Response to P87147-Handling Chemical Oxidizers SOP 401-A General Information for the Fuel Manufacturing Facility Rev. 43A SOP-401-15B-302 Area 300/400/500 Process Cleaning Rev. 017C SOP-401-17 FMF Cleaning (U) Rev. 10 & 11 21