ML22298A043

Westinghouse Columbia Fuel Fabrication Facility Integrated Inspection Report 07001151/2022003

ML22298A043
Person / Time
Site:	Westinghouse
Issue date:	10/28/2022
From:	Eric Michel NRC/RGN-II/DFFI
To:	Pope A Westinghouse
References
EN55911 IR 2022003
Download: ML22298A043 (36)

Text

October 28, 2022 EN55911 Annette Pope Plant Manger Westinghouse Electric Company 5801 Bluff Road Hopkins, SC 29061

SUBJECT:

WESTINGHOUSE COLUMBIA FUEL FABRICATION FACILITY - INTEGRATED INSPECTION REPORT 07001151/2022003

Dear Annette Pope:

This letter refers to the Nuclear Regulatory Commission inspection activities conducted from July 1, 2022 to September 30, 2022 for the Westinghouse Columbia Fuel Fabrication Facility. On July 21, 2022 and September 15, 2022 the NRC inspectors discussed the results of these inspections with you. The results of these inspections 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 10/28/22 Eric C. Michel, Chief Projects Branch 2 Division of Fuel Facility Inspection Docket No. 07001151 License No. SNM-1107

Enclosure:

As stated cc w/ encl: Distribution via LISTSERV

ML22298A043 SUNSI X Non-Sensitive X Publicly Available X

Review Sensitive Non-Publicly Available OFFICE RII/DFFI RII/DFFI RII/DFFI RII/DFFI RII/DFFI RII/DFFI T. J. Rivera-NAME L. Cooke G. Goff C. Taylor T. Sippel Vukovinsky Ortiz DATE 10/25/2022 10/25/2022 10/25/2022 10/26/2022 10/26/2022 10/27/2022 OFFICE RII/DFFI NAME E. Michel DATE 10/28/2022 U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number: 07001151 License Number: SNM-1107 Report Number: 07001151/2022003 Enterprise Identifier: I-2022-003-0056 Licensee: Westinghouse Electric Company Facility: Westinghouse Columbia Fuel Fabrication Facility Location: Hopkins, SC Inspection Dates: July 18-21, 2022, and September 12-15, 2022 Inspectors: L. Cooke, Fuel Facility Inspector G. Goff, Fuel Facilities Inspector J. Gwo, Systems Performance Analyst (subject matter expert)

J. Rivera Ortiz, Sr. Fuel Facility Project Inspector T. Sippel, Sr. Fuel Facility Projects C. Taylor, Sr. Fuel Facility Project Inspector T. Vukovinsky, Sr. Fuel Facility Project Inspector N. Peterka, Fuel Facility Inspector Approved By: Eric C. Michel, Chief Projects Branch 2 Division of Fuel Facility Inspection Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Westinghouse Columbia Fuel Fabrication Facility, 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 None.

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PLANT STATUS The Westinghouse Facility converts uranium hexafluoride (UF6) into uranium dioxide using a wet conversion process and fabricated fuel assemblies for use in commercial nuclear power 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 IP 88015 - Nuclear Criticality Safety The inspectors evaluated selected aspects of the licensees Nuclear Criticality Safety program to verify compliance with selected portions of 10 CFR 70, including 70.61, 70.62, and Appendix A, Chapter 6, Nuclear Criticality Safety (NCS) Program, 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 (CSEs), and associated assumptions and calculations, to verify compliance with 10 CFR 70 and applicable chapters of the license application. Specifically, the inspectors interviewed licensee staff and reviewed the following CSEs:

CSE-3-H, "Conversion Lines Oil Dryers and Bucket Elevators," Revision (Rev.) 11, including the review of what-if analysis, normal, credible abnormal, and non-credible accident sequences, as well as reviewing the basis for why the licensee screened certain accident sequences as non-credible CSE-4-I, "Criticality Safety Evaluation (CSE) for Processing Ash from 55-gallon Drums," Rev. 0, including the review of what-if analysis, normal, credible abnormal, and non-credible accident sequences CSE-14-B, "Criticality Safety Evaluation (CSE) for Integral Fuel Burnable Absorber (IFBA) Coaters," Rev. 10, including the review of what-if analysis, normal, credible abnormal, and non-credible accident sequences CN-CRI-06-34, "Hot Oil Dryer," Rev. 2, which was reviewed because it contained a variety of calculations and information supporting the licensee's evaluation of criticality accident sequences and IROFS in CSE-3-H CN-CRI-07-01, "Conversion Line K-Tron Recycle Feeders," Rev. 1, which was reviewed because it contained a variety of calculations and information 3

supporting the licensee's evaluation of criticality accident sequences and IROFS in CSE-3-H 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 operator and engineer interviews to verify compliance with 10 CFR 70 and applicable chapters of the license application. Specifically, the inspectors interviewed licensee staff and reviewed the following controls, and their management measures, from the CSEs listed above:

passive engineered geometry control IROFS ADUDRY-102, ADUELV-101, ADUELV-102, ADUDPXV-101, ADUDPXV-102, ADUCOND-101, and ADUKTRN-103 were inspected visually and records of geometry verification (RAF-314-1, "Criticality Safety Evaluation (CSE) Implementation Plan") were reviewed for CSE-3-H administrative geometry control IROFS ADUKTRN-101, and NCS Posting CONV08 and operating procedure COP-810910 administrative mass control IROFS ADUKTRN-102, and NCS Posting CONV08 and operating procedure COP-810910 administrative moderator control IROFS ADUKTRN-104, and NCS Posting CONV08 and operating procedure COP-810910 passive engineered mass control IROFS ADULEAK-101, and work order (WO) 114860 that was performed to verify its condition administrative moderator control IROFS ADUFIRE-902, and procedure SEPF-009-6, "Command Check Sheet - Fire Response Westinghouse Nuclear Fuel Columbia, SC," Rev. 11, as well as "Westinghouse Emergency Response Organization Site Emergency Plan Refresher Training" and "Columbia Fire Department Westinghouse Tour 2022" administrative mass control IROFS ADUELV-901, and operating procedures COP-815415 and COP-812701, and CF-81-015 forms WO 84681 and 87183, which implemented inspections of the ADU Dryer 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 chapters of the license application. Specifically, the inspectors performed the following activities:

observed a licensee NCS engineer conduct a weekly Facility Walkthrough Assessment (FWA) and reviewed a sample of recent FWA reports interviewed ADU Conversion area operators concerning criticality hazards and control methods, including the use/implementation of IROFS ADUELV-901, ADUKTRN-101, ADUKTRN-102, ADUKTRN-104, and ADUFIRE-902 4

Criticality Incident Response and Corrective Action (IP Section 02.05)

The inspectors reviewed the licensees corrective action program (CAP) to verify compliance with 10 CFR 70 and applicable chapters of the license application. Specifically, the inspectors reviewed CAP entries and related documents, and/or interviewed licensee staff concerning the following:

selected NCS-related CAP entries since the last inspection, including IR-2022-3952, IR-2022-4219, and IR-2022-4914 WO 110773 and IROFS functional check records for IR-2022-3952 o CF-81-943, "Wastewater Q-Tanks: Safety Significant Interlocks, Alarms and Passive Engineered Controls Functionality Verification Form," dated April 28, 2022 o CF-81-999, "Scrap Cage: Safety Significant Interlocks Verification Form", dated April 28, 2022 CAF-007-11, "Reportability Evaluation Form," dated May 10, 2022, for IR-2022-4219 RADIOLOGICAL CONTROLS IP 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 5, Radiation Protection, of the facilitys license application, and applicable licensee procedures.

Radiation Protection Program Implementation (IP Section 02.01)

The inspectors interviewed licensee staff and reviewed other documentation related to the implementation of the RP and RW programs to verify compliance with 10 CFR 20.1101(a),

10 CFR 61.55 and 61.56, and Section 5.1 of the license application. Specifically, the inspectors:

interviewed the RP manager and radiation safety officer regarding dose trends over the last several years in various process/handling, assembly, and storage areas and what actions the licensee took to keep dose to workers ALARA interviewed staff implementing the radioactive waste program to discuss characterization and classification of radioactive waste and shipments to off-site receptors observed workers in areas that process or store special nuclear material (SNM) wearing the required personal protective equipment (PPE), wearing the required monitoring equipment such as dosimeters, and conducting work by procedures observed contamination surveys and radiation surveys 5

Radiation Protection Program Review (IP Section 02.02)

The inspectors reviewed the licensees most recent ALARA report and most recent audit to verify compliance with 10 CFR 20.1101(c), 10 CFR 20.2102, and Sections 5.2.2 - 5.2.7 and 5.2.67 of the license application. Specifically, the inspectors:

reviewed the Annual Radiation Protection Program Review for 2020 reviewed Audit Report for the SNM-1107 Radiological Safety Program, 09/08/2021 reviewed the latest audit report of the RW program interviewed the radiation protection manager and radiation safety officer regarding the program and actions taken to keep worker dose ALARA Radiation Protection and Radioactive Waste Procedures (IP Section 02.03)

The inspectors assessed the licensees review and implementation of RP-related and RW-related procedures to verify compliance with 10 CFR 70.72 and Section 3.4.1 of the license application that no reduction in the margin of safety resulted from any significant changes to these procedures. Specifically, the inspectors reviewed:

COP-831001, "Handling, Processing, & Disposing LLRS," Revision 68 COP-831010, "Shipping Low Level Radioactive Waste," Revision 34 COP-841000, "Low Level Radioactive Scrap Handling," Revision 30 RA-219, "ALARA Program," Revision 4 RA-402, "Radioactive Material Transfers from Mfg. Buildings," Revision 42 ROP-02-012, "Washing Respiratory Protection Equipment," Revision 19 ROF-02-012-1, "Respirator Survey and Wash Log," Revision 6 ROP-02-013, "Inspection and Rebuild of Respiratory Protection Devices,"

Revision 13 ROF-02-013-1, "Mask Filter Test Form," Revision 4 ROP-01-050, "Operation of Quantfit Personnel Respirator Leak Rate Analyzer," Revision 17 ROP-04-007, "Performing In-vivo Counts," Revision 16 SYP-218, "Respiratory Protection," Revision 16 Training (IP Section 02.04)

The inspectors interviewed licensee staff and reviewed RP-related training records to verify compliance with 10 CFR 19.12 and Chapters 3 and 5 of the license application. Specifically, the inspectors reviewed documents and interviewed licensee staff concerning the following:

EHS Tech Current User Training Status RAF-125-14, "EHS HP Tech Training Checklist" RA-125, "Indoctrination, Training, and Qualification of Regulatory Personnel" HP Skills Matrix 6

Safety-Significant Events (IP Section 02.05)

The inspectors reviewed the licensees corrective action program (CAP) entries for any safety-significant RP-related and RW-related events to verify compliance with 10 CFR 20.2202 and 20.2203,10 CFR 70.50, 70.74, Part 70 Appendix A, and Sections 3.7 and 3.8 of the license application. Specifically, the inspectors:

reviewed and discussed the following corrective action entries:

o IR-2021-9582 o IR-2021-12778 o IR-2021-13327 o IR-2021-13328 o IR-2022-490 o IR-2022-921 reviewed ROP-05-065, "Personnel Contamination Event Response and Over Checks," Revision 13 reviewed ROP-07-001, "Health Physics Response to Emergency Events,"

Revision 14 Radiation Work Permits (IP Section 02.06)

The inspectors interviewed licensee staff and reviewed radiological work permits (RWPs) to verify compliance with Sections 5.2.8 - 5.2.11 of the license application. Specifically, the inspectors:

reviewed RWP 2021-07, "Remove Fuel Rods from Damaged/Returned Contaminated Fuel Assemblies," 03/23/2021 reviewed RWP 2022-03, "Cf-252 Sources Moved on Rod Scanners #3 and

1. 4," 04/02/2022 Instrument Calibration (IP Section 02.07)

The inspectors inspected survey instruments and contamination monitors to verify compliance with 10 CFR 20.1501(b) and Section 5.2.59 of the license application.

Specifically, the inspectors:

inspected survey meters/equipment for detecting alpha, beta, gamma, and neutron radiation to verify all were within calibration inspected hand and foot monitors and a whole-body contamination monitor to verify all were within calibration observed that calibration labels were placed on survey instruments used at step-off pads reviewed the following calibration procedures:

o ROP-01-032, "Source Checks for Radiation Survey/Monitoring Instruments," Revision 23 o ROP-01-059, "Calibration of the Sirius-4AB and Argos 5 AB Contamination Monitors," Revision 1 7

Instruments and Equipment (IP Section 02.08)

The inspectors interviewed licensee staff and reviewed the licensees use of radiation detecting instruments and equipment to verify compliance with 10 CFR 20.1501(a) and Sections 5.2.58 - 5.2.62 of the license application. Specifically, the inspectors observed the readiness and functionality of:

alpha probes, alpha meters, beta meters, gamma meters, and neutron detectors hand and foot monitors for contamination detection upon exiting a controlled area personnel contamination monitor (PCM) for contamination detection upon exiting a controlled area response/functional checks on survey instruments used at step-off pads Posting (IP Section 02.09)

The inspectors observed the posting of radiation areas to verify compliance with 10 CFR 20.1901 and 20.1902. Specifically, the inspectors:

observed the following type of posting: "CAUTION, RADIATION AREA" in areas where special nuclear material and radioactive waste were processed, handled, or stored reviewed procedure RA-213, "Radiation Signs," Revision 9 Container Labeling (IP Section 02.10)

The inspectors observed the exemption to the labeling requirement for packages and containers that contain radioactive material to verify compliance with 10 CFR 20.1904 and Sections 5.2.36 and 12.2.2 of the license application. Specifically, the inspectors observed the following:

a sign bearing the legend, "EVERY CONTAINER OR VESSEL IN THIS AREA MAY CONTAIN RADIOACTIVE MATERIAL, was posted at each entrance to areas for buildings in which radioactive materials are used or stored Posting of Notices (IP Section 02.11)

The inspectors observed the Posting of Notices to verify compliance with 10 CFR 19.11 and 19.12. Specifically, the inspectors:

observed NRC Form 3 posted in the cafeteria dining area and on the external bulletin board at Gate 1 reviewed RA-226, "Performing Prospective Analysis", Revision 6 Access Control (IP Section 02.12)

The inspectors interviewed the RP manager and Radiation Safety Officer and walked down areas where SNM is handled or stored to verify compliance with Chapters 5.2.33 - 5.2.41 of the license application. Specifically, the inspectors:

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confirmed through interviews that there are no high radiation or very high radiation areas on-site walked down change rooms and step-off pads to verify access points defined a contaminated and uncontaminated side observed step-off pads had postings for the proper PPE and instructions for donning/doffing the PPE 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 locked storage of SNM in vaults observed usage and control of source buttons for survey meters located at step-off pads (exits) had source buttons attached via a string and/or stored in a sleeve on the survey meter interviewed the RP manager about control and storage of licensed material Radiation Surveys (IP Section 02.14)

The inspectors interviewed licensee staff reviewed records and procedures of the licensees external radiation surveys to verify compliance with 10 CFR 20.1501(a). Specifically, the inspectors:

observed the radiation survey of an incoming shipment of LR-230 containers reviewed ROP-05-065, "Radiation Survey of Ventilation Equipment," Rev. 23 reviewed ROP-05-067, "Radiation Surveys for Radiation Producing Machines

- General Plant," Rev. 27 interviewed the RP manager and Radiation Safety Officer regarding radiation surveys with emphasis on any that had an upward trend reviewed gamma survey records pertaining to specific work areas, office areas, the fence line, and the interior of ventilation ductwork (see also the Documents Reviewed section below)

Contamination Control (IP Section 02.15)

The inspectors interviewed licensee staff and observed of the licensees contamination control measures to verify compliance with 10 CFR 20.1501(a) and Sections 5.2.29 - 5.2.41 of the license application. Specifically, the inspectors:

reviewed records ROF-05-014-17, "Daily Contamination Surveys of Step Off Pads," Revision 2 (9/6, 9/10, and 9/12 for 2022) for the main entrance to the production area, maintenance area, maintenance electrical areas, and HP remote lab reviewed records ROF-05-014-18, "Weekly Contamination Survey of Change Rooms," Revision 3 for the ADU men's change room, IFBA men's change room, URRS and maintenance men's change room, and maintenance fabrication and installation break room 9

reviewed RA-201, "Contamination Control," Revision 17 observed a contamination survey performed on the incoming shipment of LR-230 containers discussed contamination surveying with the RP technician performing the surveys Sealed Sources (IP Section 02.16)

The inspectors observed the licensees storage and control of NRC-licensed sealed sources to verify compliance with 10 CFR 20.1903(c). Specifically, the inspectors:

observed the secure storage and proper labeling of sealed sources in the RP lab and in vaults 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 applicable Section 5.2.52 of the license application. Specifically, the inspectors:

interviewed the senior health physicist regarding occupational dose records and trends in certain work areas reviewed 2021 dose records reviewed NRC Form 5 for the workers with the five highest doses Exposure Controls (IP Section 02.18)

The inspectors interviewed licensee staff and observed the process or 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 and 20.1703 and Sections 5.7.55 - 5.7.57 of the license application. Specifically, the inspectors:

observed a quantitative fit test for three types of respirators walked down/observed hoods and gloveboxes to verify that the required quarterly checks and minimum linear air velocity requirement listed in section 5.2.14 were met observed flow meters on fixed air monitors to verify all were within calibration walked down a ventilation line for one of the production units to verify containment and flow of exhaust observed cleaning activities in the respirator wash facility, reviewed daily logs in that facility, and interviewed workers interviewed the RP manager and radiation safety officer regarding areas with the highest exposure potential to workers and actions taken to keep those exposures ALARA Bioassay Program (IP Section 02.19)

The inspectors interviewed licensee staff and reviewed the bioassay program to verify compliance with 10 CFR 20.1204(b), 20.1703(c)(2) and (4)(i), 20.2103(b)(3), and Sections 5.7.51 and 5.7.56 of the license application. Specifically, the inspectors:

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reviewed RA-204, "Bioassay Program," Revision 15 reviewed electronic records of the licensee employees on an in-vitro program reviewed the daily calibration record for the lung counter (09/13/2022) and verified the sealed sources used for the calibration were U-235 sources, as required observed a lung count and reviewed the subsequent analysis report interviewed the administrator of the lung counter to verify internal dose tracking Dosimetry (IP Section 02.21)

The inspectors interviewed licensee staff, observed dosimetry being used, and reviewed electronic versions of dosimetry records to verify compliance with 10 CFR 20.1501(d) and 20.1502(a) and Sections 5.2.42 - 5.2.45 of the license application. Specifically, the inspectors:

reviewed RA-206, "Personnel Dosimetry Program," Revision 16 reviewed the certificate stating the dosimeter processor is NVLAP-accredited Dose Assessment Programmatic Review (IP Section 02.22)

The inspectors interviewed licensee staff and reviewed records and calculations related to the licensees assessment of the dose to workers to verify compliance with 10 CFR 20.1202, 20.1204, 20.1502(b), 20.2104, 20.2106 and Sections 5.2.46 - 5.2.54 of the license application. Specifically, the inspectors:

reviewed electronic versions of internal and external dose records from 2021 for randomly selected workers interviewed the RP manager and radiation safety officer regarding dose assessment, any increases in worker dose, and the licensee's actions to keep worker dose ALARA 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 Sections 5.2.2 - 5.2.7 of the license application. Specifically, the inspectors:

interviewed the licensee regarding how the Radiation Safety Program is maintaining exposures to radiation and radioactive materials ALARA, reviewed RA-219, "ALARA Program," Revision 4 reviewed RA-219-1, "ALARA Goals," Revision 18 reviewed the first three quarterly as low as reasonably achievable (ALARA)

Committee Meeting minutes for 2021 reviewed the Annual ALARA Committee Meeting Minutes for 2021 11

IP 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 reviewed the following documents and/or discussed the following areas:

reviewed the recent license application renewal commitments, specifically Chapter 10, "Environmental Protection" and Chapter 11, "Decommissioning Planning," to verify license commitments were translated into the licensee's environmental protection implementing procedures.

interviewed licensing staff to identify organization changes, if any, that would be subject to the position-specific requirements in the license application CA-007, "Corrective and Preventive Action," Rev. 49, to determine if environmental events, spills or upsets are identified as corrective action program (CAP) items or issues for inclusion into the CAP reviewed corrective actions for the following Corrective Action Program items:

o IR 2022-5876, "Soil Sampling Location 5 (LOC-5) Results" o IR 2022-4323, "High High-Level Alarm Activated from V-1087CD to T-104" o IR 2022-1734, SA-2022-84, "Environmental Sampling Procedure and Program Assessment Findings" o IR 2021-12656, "Quarterly Stormwater Routine Facility Inspection" o IR 2021-11608, "Soil Sampling Location 5 (LOC-5) Results" o IR 2021-11349," Audit # EHS-AUDIT-21-16 GEL Labs, Inc."

o IR 2021-11035, "Procedure Deficiency Discovered in Groundwater Analysis - No Safety Impact" 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 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 procedure, CA-043, "CFFF ETAPS Document Change Process,"

Rev. 1 reviewed revisions as a result of license renewal for the following procedures:

o ROP-06-001, "NPDES Daily, Weekly and Monthly Effluent Sample Collection," Rev. 57 o ROP-06-006, "Collection of Routine NRC-Required Environmental Samples," Rev. 40 12

o ROP-06-007, "Groundwater Well Sampling," Rev. 35, o ROF-06-007-2, "Low Flow Groundwater Sample Collection Record,"

Rev. 7 o ROP-06-010, "Quarterly Storm Water Monitoring and Visual Inspection," Rev. 9 observed collection of environmental samples by environmental technician for the following procedures:

o ROP-06-001, "NPDES Daily, Weekly and Monthly Effluent Sample Collection," Rev. 57 for collection of liquid effluent prior to discharged from wastewater treatment facility o ROP-06-006, "Collection of Routine NRC-Required Environmental Samples," Rev. 40, for weekly surface water locations: Causeway, Gator Pond, Lower Sunset Lake and Spillway 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 completed the following activities:

reviewed audit procedure RA-106, "Regulatory Component Audits at CFFF,"

Rev. 42 reviewed the following audits and schedule:

o EHS-AUDIT-21-11, "Triennial Audit Report for the SNM-1107 Environmental Protection," dated 8/31/21 o EHS-AUDIT-22-7, "Formal Compliance Audit," dated 8/11/22 o 2021 Regulatory Component Audit Status dated 3/14/22 reviewed approved vendor list of items from the "Environmental Health and Safety Quality Policy Manual," dated 2/28/22 reviewed audits for the following vendors:

o EHS-AUDIT-21-16, "Supplier Audit of GEL, Labs LLC," dated 10/18/21, the vendor provides environmental, radiological, and bioassay laboratory analytical services o EHS-AUDIT-21-17, "Supplier Audit of Carolina Technical Services Inc.," dated October 26, 2021, the vendor provides surface water, sediment, and fish sample extraction services 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:

Selected event notifications and conducted interviews with licensee staff to determine if environmental events as defined by the license application and 10 CFR 70.619 (c)(3) were required to be reported for 2020 through 2022.

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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 reviewed the following:

training plans and a sample of qualification records for the following:

o environmental technician o assay operator o wastewater operators 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:

reviewed procedure ROP-06-001, "NPDES Daily, Weekly and Monthly Effluent Sample Collection," Rev. 57 reviewed procedure ROP-06-006, "Collection of Routine NRC-Required Environmental Samples," Rev. 40 reviewed procedure MCP-202063, "Daily River Discharge pH Calibration,"

Rev. 15 observed daily and weekly liquid effluent collection by environmental technician observed calibration of equipment labels used to collect daily and weekly samples reviewed two months of monthly batch results from the wastewater treatment facility to determine whether results were within regulatory limits for uranium and technetium-99 liquid effluents.

reviewed calibration records for in-line gamma spectroscopy monitors located in the main plant building prior to transfer from in-plant final pump out tank to wastewater treatment facility 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:

The licensee does not release liquid effluents to the municipal sanitary sewer; therefore, this chapter does not apply.

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 14

10 CFR 20.1101, 10 CFR 20.2103, and the license application. Specifically, the inspectors completed the following activities:

reviewed procedure ROP-06-002, "Roof Effluent Air Sampling and Counting,"

Rev. 31 reviewed the concentration calculation for the air roof effluent to determine whether the licensee used the appropriate assumptions for the calculations observed an environmental technician collect 24 roof air stack effluent samples for the Plant Main building interviewed the environmental lab technicians regarding general work responsibilities, significant changes to the calculation processes, unevaluated release concerns, and the process for reporting elevated stack samples observed counting of previous day air samples on the Tennelec and IMATIC measurement system and reviewed the results of daily functional checks for the Tennelec and IMATIC measurement system 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:

conducted a walkdown of the following IROFS:

o 901, "Diked Pad for UN Bulk Storage and UN Offloading Areas" o 912, "Tank Wall for UN Storage Tanks" o 915, "Expanded UN Containment Area for UN Storage Tanks" o 905, "Plant-SEP-905, Outfall Valve "C" reviewed IROFS 913, "Best Management Practice (BMP) Plan," dated April 2022 reviewed the following management measures results:

o "52 Weeks OM85018 SI-SAFETY - UN Pad Inspection," dated May 22, 2022 (IROFS 901) o "52 Weeks OM85018 SI-SAFETY - UN Pad Inspection," dated May 17, 2021 (IROFS 901 & 915))

o "13 Week PM 85001 SI-Safety Sluice Gate Valves," dated 9/7/22 (IROFS Plant-SEP 905) o Work Order 790948, "UN Storage Tank Internal Mechanical Integrity Inspection 54 months," dated April 15, 2020 (IROFS 912) o Work Order 827956, "UN Bulk Storage Tanks External Mechanical Integrity Inspection 5 year," dated March 25, 2019 (IROFS 912) reviewed the following procedures:

o COP-836016, "UN Tanks Bulk Storage- Emergency Procedures," Rev.

16 o SEPF-009-28, "Command Check Sheet- Seismic Event," Rev. 2 o COP-836047, "Uranyl Nitrate Offloading from LR-230 Containers,"

Rev. 24 15

Semiannual Effluent Reports (IP Section 02.10)

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

Reviewed the Semi-Annual Discharge Reports results for 2020 through 1st half of 2022 Quality Control of Analytical Measurements (IP Section 02.11)

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

Specifically, the inspectors completed the following activities:

reviewed procedure ROP-01-028, "Calibration of Flowmeters," Rev. 13 reviewed procedure ROP-01-040, "Background and Efficiency Determination and Calibration of the iMATIC Automatic Sample Counters," Rev. 3 observed daily roof air stack sample count from previous day on Tennelec measurement system, observed daily functional count and checks for Tennelec measurement system interviewed environmental technician on daily activities, unplanned event release evaluations and process for reporting elevated air stack samples reviewed IMATIC Measurement Control Standard/Background Count Log dated 09/15/22 reviewed Tennelec Measurement Control Standard/Background Count Log dated 09/15/22 reviewed approved vendor, "GEL Laboratories, Chain of Custody and Analytical Request," dated 6/1/2021 for soil and vegetation samples reviewed calibration record, "Flowmeter Verification for Ambient Air," dated 8/26/22 (Test Meter SN: 12645) for sample locations: Station 1 (Hwy 48);

Station 2 (East Side of Plant); Station 3 (Parking Lot); and Station 4 (SW of plant in field)

Public Dose Analysis (IP Section 02.12)

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

reviewed procedure RA-413, "NRC Semi-Annual Effluent Discharge Report,"

Rev. 6 reviewed and discussed with the licensee the whole body and organ dose calculation assumptions using licensee guidance documents and EPA COMPLY code to determine whether the licensee used appropriate inputs for dose assessment from effluents 16

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 reviewed the following procedures and completed the following activities:

RA-407, "Sampling Congaree River Surface Water and Fish and Site Sediments," Rev. 13 ROP-06-006, "Collection of Routine NRC Required Environmental Samples,"

Rev. 40 RA-400, "Attachment 1, Effluent Limitations and Monitoring Requirements,"

Rev. 15 ROP-06-003, "Ambient Environmental Air Monitoring for Radioactivity," Rev.

17 ROP-06-007, "Groundwater Well Sampling," Rev. 35 ROP-06-001, "NPDES Daily, Weekly, and Monthly Effluent Sample Collection," Rev. 57 reviewed the results for Certificate of Analysis (Gel Laboratories, LLC) dated from January 2022 through July 2022 for the following samples:

o Wastewater o SW Spillway o SW Causeway o SW Roadway o SW Entrance o SW Exit o Gator Pond o Lower Sunset Lake reviewed the results from the "2020-2021 Annual Groundwater Monitoring Report," dated September 2021 "Appendix D, Plume Analytics Technical Memo - AECOM," dated September 27, 2021 reviewed results of annual fish and sediment samples for 2020 and 2021 reviewed result of bi-annual soil and vegetation samples for 2020, 2021 and May 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 reviewed the following procedures and records:

procedure RA-433, "Environmental Remediation, Rev. 2 procedure RA-434, "Environmental Data Management," Rev. 2 procedure RA-435, "Conceptual Site Model Development," Rev. 1 procedure ROS-06-007-1, "Groundwater Wells and Sampling Parameters,"

Rev. 2 procedure ROP-06-007, "Groundwater Well Sampling," Rev. 35 17

"2022 CFFF Environmental Priorities and Risks," Rev. 64 to determine whether licensee maintains records important to decommissioning RA-137, "Decommissioning Record Keeping," Rev.1 to determine whether licensee maintains records important to decommissioning "Spills Location DWG No. 601F03CV01," dated 4/23/19 to determine whether licensee maintains records important to decommissioning "Westinghouse CFFF Spill Tracking Sheet," dated 10/26/2021, to determine whether licensee provides description of spills and identifies contamination of concern, residual activity, mitigation actions, wells, groundwater impact "Remedial Investigation Report, Appendix Y, Conceptual Site Model-AECOM," Rev. 4 to determine whether licensee is aware, and tracks known spills, spread of contamination (residual and subsurface) in and around the facility, has established an early leakage detection system, and utilizes appropriate inputs and outputs for ongoing remediation and decommissioning efforts "Conceptual Site Model Revision Log," Rev. 4 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 conducted the following activities:

reviewed procedures that described the process for waste classification and characterization, and waste storage:

COP- 841000, "Low Level Radioactive Scrap Handling," Rev. 30 COP- 831001, "Handling, Processing and Disposing Low Level Radioactive Scrap (LLRS)," Rev. 68 COP- 831010, "Shipping Low Level Radioactive Waste," Rev. 34 WS-53455-0-248, "Waste Manifest," US Ecology, solid uranium oxide, pond sediment dated 8/23/21 ISEU100009-266, "Waste Manifest," Specialty Transport, solid uranium oxide, debris, compacted filter media dated 8/2/22 conducted walkdowns of the following areas: low-level waste storage facility, uranium recovery and recycle services (URRS), solvent extraction, and UF6 Bay areas to observe the physical condition of waste containers, stacking of waste containers, labeling of the waste containers and segregation of waste in these areas 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:

conducted a walkdown of the wastewater treatment facility and observed daily operations and batch sampling points for liquid effluents 18

reviewed two months of monthly batch results from the wastewater treatment facility to determine whether results were within regulatory limits for uranium and technetium-99 liquid effluents.

reviewed calibration records for in-line gamma spectroscopy monitors located in the main plant building prior to transfer from in-plant final pump out tank to wastewater treatment facility reviewed effluent records to determine whether the licensee took appropriate actions if ALARA goals and investigational levels were exceeded per license application commitments reviewed procedure COP-831205, "Filling, Sampling and Discharging T-1140, North and South Lagoons," Rev. 48 reviewed the following ventilation inspection records for S-1030 Ventilation Ducts in the Main Plant building:

o "52 Week Ventilation Duct Integrity (CONV-1008 - 1008 Scrubber Ventilation System) Ammonia Fume Scrubber," dated 4/12/22 o "8 Week HEPA Filter House Inspection (CONV-1030 - 1030 Scrubber Ventilation System) FL-1030B Filter House," dated 8/23/22 o "13 Week Gamma Survey of Ventilation System (CONV-1008 Scrubber Ventilation System) Ammonia Fume Scrubber," dated 9/11/22 o Work Order 99530, "S-1030 Ventilation Ducts Requiring Inspection (SSC-VENT-S1030-111)," dated 3/22/22 FACILITY SUPPORT IP 88070 - Permanent Plant Modifications The inspectors conducted a review to verify the licensee had established and implemented a configuration management system to evaluate, implement, and track changes to the facility in accordance with the applicable requirements in 10 CFR 70.72 and the license application, Chapter 3, Conduct of Operations." The inspectors review also verified the licensee had established management measures for changes to the facility in accordance with 10 CFR 70, Subpart H and the license application, and those modifications involving new processes, if any, met the requirements in 10 CFR 70.64.

Sample Selection (IP Section 02.01)

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

CCF 19041, Replace Existing SBG-3 and SBG-4 with New Diesel Generators SBG-3 and SBG-4 (ISA-03 ADU Conversion)

CCF 20257, Increase P1081 Pump from 1.0 GPM to 3.0-6.0 GPM (ISA-07 Solvent Extraction)

CCF 20322, Replace Obsolete V-1085 Transfer Line Valves (ISA-07 Solvent Extraction) 19

CCF 20335, Replacement of SOLX Solvent Flow Transmitter FT-1491 (ISA-07 Solvent Extraction)

CCF 20381, Waterglass Undersized Vacuum Breaks T1160B & T1160C WT-121 & WT-139 (ISA-15 URRS Wastewater Treatment System)

CCF 21045, SOLX Piping Modifications V1484 & V1081 (ISA-07 Solvent Extraction)

CCF 21176 H2 Maximum Flow Shut Off Valve Bypass Piping (ISA-01 Plant Ventilation System)

CCF 21235, URRS SOLX P1081 Pump Option for Low and High GPM Pump Flow Rate (ISA-07 Solvent Extraction)

CCF 21306, Uranyl Nitrate Piping Degradation (ISA-11 Scrap Uranium Processing)

CCF-D-22043-0, Conversion Piping Upgrade - SOLX Line Material Specification Change (ISA-07 Solvent Extraction)

Facility Change/Modification Process (IP Section 02.02)

The inspectors reviewed the selected modifications listed in Section 02.01 above to verify the licensee implemented a configuration management system in accordance with 10 CFR 70.72 and the conditions of the license. Specifically, the inspectors conducted the inspections activities listed below:

reviewed the following procedures to verify the configuration management system was documented in written procedures and the procedures addressed the aspects in 10 CFR 70.72(a):

o TA-500, Columbia Manufacturing Plant Configuration Control, Rev. 41 o RA-104, Regulatory Review of Configuration Change Authorization, Rev. 32 and 33 interviewed licensee staff; reviewed technical and regulatory evaluations, and performed walk-downs of the modifications selected in Section 02.01 above to verify the licensee provided valid technical bases to support the determination of whether an amendment to the license was required based on the criteria in 10 CFR 70.72(c) reviewed facility documentation associated with the selected plant modifications to verify the affected documents were updated promptly in accordance with 10 CFR 70.72(e) or the timeframe outlined in the license reviewed configuration management system records to verify the licensee submitted a summary with facility changes and revised ISA Summary pages to the NRC in accordance with 10 CFR 70.72(d)

Management Measures (IP Section 02.03)

For the selected modifications, the inspectors reviewed the management measures established for affected IROFS to verify the management measures ensured the IROFS were available and reliable to perform their intended function as required by 10 CFR 70.61 and the conditions of the license. Specifically, the inspectors conducted the inspection activities listed below:

reviewed management measures established for IROFS SBG-401, SBG-402, SBG-901, and SBG-902 as a result of CCF 19041 20

reviewed management measures for IROFS CHEM-407-H associated with CCF 21176 reviewed condition reports to determine whether the licensee identified configuration management, post modification testing, and/or plant modification issues and corrected the condition in accordance with the requirements in the license application reviewed the audit records listed below related to the configuration management system and interviewed licensee staff to verify the scope and frequency of audits, as well as corrective actions for audit findings, were conducted in accordance with the license application and facility procedures.

o EHS-AUDIT-21-14, Regulatory Component Audit for Configuration Management, Audits and Assessments; Record Keeping and Reporting, 11/16/2021 o RA-106, Regulatory Component Audits at the Columbia Fuel Fabrication Facility, Rev. 42 o Corrective Action Program entries for audit findings: IR-2021-12497, IR-2021-12492, and IR-12498 License application Changes (IP Section 02.04)

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

reviewed the license application changes submitted to the NRC on January 26, 2021, (ADAMS Accession Number ML21026A323) to verify the licensee followed their approved change process reviewed changes to the license application as a result of the plant modifications listed in Section 02.01 of this inspection report New Processes at Existing Facilities (IP Section 02.05)

The inspectors interviewed licensee staff and conducted walk-downs to determine whether new fabrication processes were installed since the last NRC inspection in this area. The licensee had not implemented any new facility processes at the time of the inspection.

Therefore, the inspectors review did not include evaluations of whether the licensee addressed the baseline design criteria and defense-in-depth as stipulated in 10 CFR 70.64.

Records Retention (IP Section 02.06)

The inspectors reviewed the configuration management system application and a sample of plant documents impacted by the selected modifications to verify the licensee-maintained records of facility changes in accordance with the license requirements and 10 CFR 70.72.

The documents selected for review are listed in the "Documents Reviewed" section of this inspection report and included the following categories:

operating procedures system drawings 21

ISA Summary license application fire hazard analysis criticality safety evaluations records management procedure INSPECTION RESULTS Minor Violation 88015 Minor Violation: An event follow-up inspection was conducted from May 31 to June 1, 2022, for EN55911. The event resulted in the reported loss or degradation of IROFS in the Waterglass system which caused a failure to meet the performance requirements of 10 CFR 70.61. Details can be found in inspection report 70-1151/2022-002 (ML22200A247). The inspectors reviewed the 60-day report (ML22203A142).

Screening: The inspectors determined the violation was minor. Per NRC Manual Chapter 0616, Fuel Cycle Safety and Safeguards Inspection Reports, Appendix B, Minor/More-than-Minor Examples, this issue aligns closely with example 1a. This issue is considered minor because the failure to complete CF-83-213 and the transfer of uranium bearing material did not adversely affect the overall concentration in T-1160.

Enforcement: The licensee took immediate corrective actions to restore compliance by shutting down the system and performing the required samples to verify the tanks were below criticality safety limits. Additionally, the licensee has taken the following corrective actions:

The associated procedure COP-835024 has been revised to specify that the V-1170 tanks shall be isolated, and the valves locked when the tanks are sampled to preclude the addition of uranium into the tank and invalidate the sample results until the time of transfer.

ISA-15, Wastewater Treatment System and associated calculation note CNSB 06 have been updated to justify multiple failures of WT-165, WT-166, WT-171, WT-172, WT-175 and WT-176 before the performance requirements would be exceeded.

The controls on system inputs limit the uranium content such that more than 3 consecutive failures of the IROFS would have to occur before the uranium content in T-1160B would approach the conservatively calculated limits, even when considering maximum possible uranium concentrations.

This failure to comply with Safety Condition S-1 of the Westinghouse Materials License and license application Section 3.4.1, Procedure Structure, constitutes a minor violation that is not subject to enforcement action in accordance with the "NRC Enforcement Policy."

EN55911 is closed.

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

On September 15, 2022, the inspectors presented the integrated inspection results to Annette Pope and other members of the licensee staff.

On July 21, 2022, the inspectors presented the NCS and plant modification inspection results to Annette Pope and other members of the licensee staff.

22

23 DOCUMENTS REVIEWED Inspection Type Designation Description or Title Revision or Procedure Date 88015 Corrective Action IR-2022-3952, IR- NCS related CAP entries Documents 2022-4219, IR-2022-4914 Engineering CN-CRI-06-34 Hot Oil Dryer Rev. 2 Evaluation CN-CRI-07-01 Conversion Line K-Tron Recycle Feeders Rev. 1 CN-SB-09-10 Conversion Lines Oil Dryers and Bucket Elevators Criticality Rev. 2 Accident Potential CSE-14-B Criticality Safety Evaluation (CSE) for Integral Fuel Burnable Rev. 10 Absorber (IFBA) Coaters CSE-3-H Conversion Lines Oil Dryers and Bucket Elevators Rev. 11 CSE-4-I Criticality Safety Evaluation (CSE) for Processing Ash from Rev. 0 55-gallon Drums Miscellaneous Columbia Fire Department Westinghouse Tour 2022 Westinghouse Emergency Response Organization Site Emergency Plan Refresher Training CN-CRI-20-003 NCS Manual Rev. 5 CONV08 Criticality Requirements Stratblender K-tron Feed Hood Rev. 2 RAF-314-1 Criticality Safety Evaluation (CSE) Implementation Plan, for 06/04/2009 CSE-3-H Operability CF-81-943 Wastewater Q-Tanks: Safety Significant Interlocks, Alarms 04/28/2022 Evaluations and Passive Engineered Controls Functionality Verification Form CF-81-999 Scrap Cage: Safety Significant Interlocks Verification Form 04/28/2022 Procedures CF-81-015 Conversion Field Data Checklist for Conversion Line Rev. 75 COP-810910 Feeding Dry Material Via the K-Tron Feeder Rev. 29 COP-812701 EL-x27 Powder Elevator Rev. 5 COP-815415 Inspection of Non-Favorable Geometry Enclosures Rev. 5 RA-313 Criticality Safety Evaluations (CSEs) Rev. 16 SEPF-009-6 Command Check Sheet - Fire Response Westinghouse Rev. 11 Nuclear Fuel Columbia, SC Self-Assessments RAF-316-1 Nuclear Criticality Safety Checklist for NCS Facility 07/12/2022 Walkthrough Assessments, 24

Inspection Type Designation Description or Title Revision or Procedure Date Conversion - Chief Operations and Various Containers RAF-316-1 Nuclear Criticality Safety Checklist for NCS Facility 07/12/2022 Walkthrough Assessments, Outside URRS RAF-316-1 Nuclear Criticality Safety Checklist for NCS Facility 07/12/2022 Walkthrough Assessments, SOLX Operator RAF-316-1 Nuclear Criticality Safety Checklist for NCS Facility 07/12/2022 Walkthrough Assessments, Conversion - Conversion Operations and Various Containers RAF-316-1 Nuclear Criticality Safety Checklist for NCS Facility 07/12/2022 Walkthrough Assessments, Conversion - Scrap Cage Operations and Various Containers Work Orders 110773

Description:

Work Order verifying IROFS functionality 114860 PM20430 SI-SAFETY, CONVERSION ROOFINSPECTION - 06/03/2022 52 WEEK PM 84681 52 Weeks PM81472 ADU Dryer - 52 Week PM 07/08/2022 87183 2 Years PM81473 ADU Dryer - 104 Week PM 07/19/2022 88030 Corrective Action IR 2021-13327 Increasing Trend Identified in Number of Routine In-Vivo 12/09/2021 Documents Results Exceeding MDA IR 2021-13328 Increasing Trend in EDEX 12/09/2021 IR-2021-1044 RB: Alert Limit Exceeded for Chapter CL3-004, on 01/29/2021 Conversion Lin 3 Torit Ductwork IR-2021-12778 Respirator Facility Employees Expired or Have Never Been 11/24/2021 Qualified on EHS-NSQT-002, Nuclear Safety Qualification Training Oral Review Board IR-2021-9582 Int OR Audit - Audit # EHS-AUDIT-21-10, SNM-1107 09/02/2021 Radiological Safety Program, EHS Operations Non-conformances IR-2022-4352 Unable to send dose information to REIRS in accordance w 05/10/2022 ith the requirements of 10 CFR 20.2206(c)

IR-2022-4661 NRC Operational Safety inspection exited w ith a Minor 05/20/2022 25

Inspection Type Designation Description or Title Revision or Procedure Date Violation for failure to provide NRC Form 5/Dose Information to REIRS by the April 30th deadline per 10 CFR 20.2206(c)

IR-2022-490 SA-2022-32 Training Record issues identified during EHS 01/20/2022 training record Self Assessment Review .

Miscellaneous Chart of URRS Waste Streams CY2000 ALARA Goal Exceedance. Individual, Collective, and Average TEDE (10 highest TEDEs)

Uniform Straight Bill of Lading (LR-230) 09/02/2022 Flowcharts of Combustible/Non-Combustible Trash and Low Level Radioactive Waste Shipments In Vivo Log Analysis (records) August -

September 2022 Radiation Safety Organizational Chart HP Skills Matrix 09/15/2022 EHS Current User Training Status for three individuals 09/15/2022

1. 33920 In Vivo Analysis Report 09/13/2022 20220915142552 Radioactive Shipment Smear Results 09/15/2022 831001-1 Drum Concentration Limits for Shipment Revision 0 843002-3 Movable Non-Favorable Geometry (NFG) Container List Revision 19 CF-83-111 URRS ChAMPS Material Designations Revision 28 EHS-Audit-19-2 Regulatory Component Audit of Thermo Fisher Scientific 06/06/2019 Process Instruments NRC Form 5 Occupational Exposure Record for A Monitoring Period (for 01/01/2021 -

Equivalent five workers) 12/31/2021 RAF-125-14 EHS, Operations, HP Technician, Radiation Protection Rev. 6 Training Checklist ROF-05-028-1 Work Restriction Form 08/24/2020 ROF-05-046-1 Inventory and Leak Test of Sealed Sources 01/06/2022 and 07/01/2022 ROF-05-062-6 Ventilation Survey Follow-Up Form (February and April Revision 5 2021)

Procedures COP-831001 Handling, Processing, & Disposing LLRS Revision 68 26

Inspection Type Designation Description or Title Revision or Procedure Date COP-831010 Shipping Low Level Radioactive Waste Revision 34 COP-841000 Low Level Radioactive Scrap Handling Revision 30 RA-125 Indoctrination, Training, and Qualification of Regulatory Rev. 26 Component Personnel RA-201 Contamination Control Revision 17 RA-203 General HP Rules and Recommendations Revision 33 RA-204 Bioassay Program Revision 15 RA-206 Personnel Dosimetry Program Revision 16 RA-207 Radiation Work Permit Revision 23 RA-213 Radiation Signs Revision 9 RA-219 ALARA Program Revision 4 RA-219-1 ALARA Goals Revision 18 RA-226 Performing Prospective Analysis Revision 6 RA-402 Radioactive Material Transfers from Mfg. Buildings Revision 42 RAF-207-1 Radiation Work Permit - Job Description, Pre-Job Review, Revision 18 Working Conditions, and Required PPE RAF-207-2 Radiation Work Permit - Personnel Qualifications Revision 9 RAF-207-3 Radiation Work Permit - Approved Personnel Revision 1 ROF-02-012-1 Respirator Survey and Wash Log Revision 6 ROF-02-013-1 Mask Filter Test Form Revision 4 ROP-01-032 Source Checks for Radiation Survey/Monitoring Instruments Revision 23 ROP-01-036 HEPA Filter System Leak Test Revision 19 ROP-01-050 Operation of Quantifit Personnel Respirator Leak Rate Revision 17 Analyzer ROP-01-059 Calibration of the Sirius-4AB and Argos 5 AB Contamination Revision 1 Monitors ROP-02-008 Surveys of Incoming and Outgoing Shipments of Radioactive Revision 33 Materials ROP-02-010 Surveillance of Uranium Shipments from Outside Sources Revision 24 ROP-02-012 Washing Respiratory Protection Equipment Revision 19 ROP-02-012-1 Respirator Survey and Wash Log Revision 6 ROP-02-013 Inspection and Rebuild of Respiratory Protection Devices Revision 13 ROP-02-013-1 Mask Filter Test Form Revision 4 27

Inspection Type Designation Description or Title Revision or Procedure Date ROP-03-001 Personnel Dosimetry System Revision 22 ROP-03-002 Personnel Exposure System - Guide Revision 7 ROP-03-003 Collecting Dosimetry Badges Revision 0 ROP-04-007 Performing In-vivo Counts Revision 16 ROP-05-002 Performing Smear Surveys Revision 17 ROP-05-014 Performing Contamination Surveys of the Westinghouse Revision 34 Facility ROP-05-028 Employee Work Restrictions Revision 23 ROP-05-060 Ventilation Velocity Checks Revision 16 ROP-05-062 Radiation Survey of Ventilation Equipment Revision 23 ROP-05-065 Personnel Contamination Event Response and Over Checks Revision 13 ROP-05-067 Radiation Surveys for Radiation Producing Machines - Revision 27 General Plant ROP-05-069 Quarterly Air Sampling of In-plant Recirculating Ventilation Revision 11 Systems ROP-07-001 Health Physics Response to Emergency Events Revision 14 SYP-218 Respiratory Protection Revision 16 Radiation ROF-02-008-1 Surveys of Incoming Shipments of Radioactive Materials 09/15/2022 Surveys ROF-05-014-17 Daily Contamination Surveys of Step Off Pads 09/06/22 - Rev. 2 09/10/22, 09/12/22 ROF-05-014-18 Weekly Contamination Survey of Change Rooms 08/18/22 Rev. 3 ROF-05-062-10 Quarterly - S-7159 Survey (Calendar Year 2021) Revision 1 ROF-05-062-11 Quarterly - S-958 Survey (Calendar Year 2021) Revision 1 ROF-05-062-12 Ventilation Systems Equipment Radiation Survey Quarterly - Revision 1 FL-973 Survey (Calendar Year 2021)

ROF-05-062-13 Monthly - Conversion Torit Survey (January - December Revision 1 2021)

ROF-05-062-14 Monthly - Pellet Torit Survey (January - December 2021) Revision 0 ROF-05-062-3 Ventilation System Radiation Survey Action Reports Revision 20 (Calendar Year 2021)

ROF-05-062-4 Ventilation Systems Equipment - Quarterly Radiation Revision 22 Surveys (Calendar Year 2021)

ROF-05-062-7 Monthly - S-1030 Survey (January - December 2021) Revision 1 28

Inspection Type Designation Description or Title Revision or Procedure Date ROF-05-062-8 Ventilation Systems Equipment Radiation Survey Monthly - Revision 2 S-2A/2B Survey (January - December 2021)

ROF-05-062-9 Quarterly - S-1008 Survey (Calendar Year 2021) Revision 0 ROF-05-067-10 Mechanical Area Gamma Survey First three calendar quarters of 2022 ROF-05-067-11 Outside Area Gamma Survey First three quarters of 2022 ROF-05-067-12 Quarterly Perimeter Fence Gamma Survey First three quarters of 2022 ROF-05-067-15 Office Area 1 Gamma Survey First three quarters of 2022 ROF-05-067-16 Office Area 2 Gamma Survey First three quarters of 2022 ROF-05-067-17 Development & Met Labs Gamma Survey First three quarters of 2022 ROF-05-067-7 ERBIA Area Gamma Survey First three quarters of 2022 ROF-05-067-8 Chemical Area Gamma Survey First three quarters of 2022 ROF-05-067-9 Quarterly IFBA Gamma Survey First three quarters of 2022 Radiation Work 2021-07 Remove Fuel Rods from Damaged/Returned Contaminated 03/23/2021 Permits (RWPs) Fuel Assemblies 2022-003 Cf-252 Source Moves on Rod Scanners #3 and #4 04/02/2022 29

Inspection Type Designation Description or Title Revision or Procedure Date Self-Assessments EHS-AUDIT Audit Report for the SNM-1107 Radiological Safety Program 09/08/2021 10 EHS-AUDIT Audit Report for the SNM-1107 Environmental Protection August 31, 11 Program (contains radiological waste chapter) 2021 88045 Calibration Tennelec Measurement Control Standard/Background Count 9/15/22 Records Log IMATIC Measurement Control Standard/Background Count 9/15/2022 Log RY-S-1160A1 Gamma Monitor A1, Q-Tanks to Waterglass 04/20/2022 RY-S-1160A2 Gamma Monitor A2, Q-Tanks to Waterglass 04/20/2022 RY-S-1160A3 Gamma Monitor A3, Q-Tanks to Waterglass 04/20/2022 Corrective Action 2022-1734, SA- Environmental Sampling Procedure and Program Documents 2022-84 Assessment Findings IR 2021-11035 Procedure Deficiency Discovered in Groundwater Analysis -

No Safety Impact IR 2021-11349 Audit # EHS-AUDIT-21-16 GEL Labs, Inc.

IR 2021-12656 Quarterly Stormwater Routine Facility Inspection IR 2022-4332 High High Level Alarm Activated from V-1087CD to T-1041 IR 2022-5876 Soil Sampling Location 5 (LOC-5) Results Drawings 600F02REF01 RAF-137-1, Decommissioning Recordkeeping 10 CFR (Plant Grounds) 70.25(g)(3) Required List of Areas 601F03CV01 Spills Location 04/23/2019 Miscellaneous Westinghouse CFFF Spill Tracking Sheet 10/26/2021 52 Week Ventilation Duct Integrity Inspection (CONV-1008 - 04/12/2022 1008 Scrubber Ventilation System) Ammonia Fume Scrubber 8 Week HEPA Filter House Inspection (CONV-1030 - 1030 08/23/2022 Scrubber Ventilation System) FL-1030B Filter House 13 Week Gamma Survey of Ventilation System (CONV-1008 09/11/2022 Scrubber Ventilation System) Ammonia Fume Scrubber Westinghouse 2020-2021 Annual Groundwater Monitoring 11/03/2021 Report Remedial Investigation Report, Appendix Y, Conceptual Site Rev. 4 Model- AECOM, 30

Inspection Type Designation Description or Title Revision or Procedure Date 52 Weeks OM85018 SI-SAFETY - UN Pad Inspection 5/22/2022 52 Weeks OM85018 SI-SAFETY - UN Pad Inspection 5/17/2021 RA-137 Decommissioning Record Keeping Rev. 1 Procedures CA-043 CFFF ETAPS Document Change Process Rev. 1 COP- 831001 Handling, Processing and Disposing Low Level Radioactive Rev. 68 Scrap (LLRS, COP- 841000 Low Level Radioactive Scrap Handling Rev. 30 COP-831205 Filling, Sampling and Discharging T-1140, North and South Rev. 48 Lagoons COP-836016 UN Tanks Bulk Storage- Emergency Procedures Rev. 16 COP-836047 Uranyl Nitrate Offloading from LR-230 Containers Rev. 24 RA-106 Regulatory Component Audits at CFFF Rev. 42 RA-400 Attachment 1, Effluent Limitations and Monitoring Rev. 15 Requirements RA-407 Sampling Congaree River Surface Water and Fish and Site Rev. 13 Sediments RA-413 NRC Semi-Annual Effluent Discharge Report Rev. 6 RA-433 Environmental Remediation Rev. 2 RA-434 Environmental Data Management Rev. 2 RA-435 Conceptual Site Model Development Rev. 1 ROF-06-007-2 Low Flow Groundwater Sample Collection Record Rev. 7 ROP-06-001 NPDES Daily, Weekly and Monthly Effluent Sample Rev. 57 Collection ROP-06-002 Roof Effluent Air Sampling and Counting Rev 31 ROP-06-003 Ambient Environmental Air Monitoring for Radioactivity Rev. 17 ROP-06-006 Collection of Routine NRC-Required Environmental Samples Rev. 40 ROP-06-007 Groundwater Well Sampling Rev. 35 ROP-06-010 Quarterly Storm Water Monitoring and Visual Inspection Rev. 9 ROS-06-007-1 Groundwater Wells and Sampling Parameters Rev. 2 SEPF-009-28 Command Check Sheet- Seismic Event Rev. 2 Self-Assessments EHS-AUDIT Audit Report for the SNM-1107 Environmental Protection 8/31/21 11 EHS-AUDIT Supplier Audit of GEL,, Labs LLC 10/18/21 31

Inspection Type Designation Description or Title Revision or Procedure Date 16 EHS-AUDIT Supplier Audit of Carolina Technical Services Inc. 10/26/2021 17 EHS-AUDIT-22-7 Formal Compliance Audit 8/11/22 Shipping Records ISEU100009-266 Waste Manifest Specialty Transport 08/02/2022 S-53455-0-248 Waste Manifest, US Ecology 08/23/2021 Work Orders 790948 UN Storage Tank Internal Mechanical Integrity Inspection 54 1/23/2020 months 827956 UN Bulk Storage Tanks External Mechanical Integrity 3/25/2019 Inspection 5 year 99530 S-1030 Ventilation Ducts Requiring Inspection (SSC-VENT- 03/22/2022 S1030-111 88070 Corrective Action IR-2021-13347 Failure to Follow TA-500 Configuration Control and SYP-223 12/10/2021 Documents IR-2022-4811 Evaluation of Changes Affecting Current 304L SS Processes 5/25/2022 Corrective Action IR-2022-6455 Hydrogen Excess Flow Valve Bypass Valve Not Locked per 7/20/2022 Documents MCP-203530 Resulting from Inspection Drawings 301F01PI01, SOLX I Feed Tanks Rev. 36 Sheet 2 301F01PI01, SOLX I Feed Tanks Rev. C1 Sheet 2 301F01PI01, Solvent Extraction I Rev. C1 Sheet 3 301F01PI01, Solvent Extraction I Rev. C1 Sheet 3 301F01PI01, Solvent Extraction I Rev. C1 Sheet 3 301F01PI02, Solvent Extraction II Rev. C1 Sheet 1 301F01PI02, Solvent Extraction II Rev. C1 Sheet 1 301F02PI01, UN Product Concentrator System I & II Rev. C2 Sheet 1 32

Inspection Type Designation Description or Title Revision or Procedure Date 301F02PI01, UN Product Concentrator System I & II Rev. C1 Sheet 1 301F02PI01, UN Product Concentrator System I & II Rev. C2 Sheet 1 301F02PI02, UNH Product Holding Tank V-1487A Rev. 21 Sheet 2 333F08PI01, Liquid Waste Storage Columns Rev. 42 Sheet 1 620F02PI01, Waterglass Feed / Storage Tanks P&ID Rev. 42 Sheet 2 620F05EQ01, Fume Hood, Ammonia Vent System 05 Sheet 1 620F05PI01, Ammonia Scrubber Process Vent System Ammonia Fume Rev. 10 Sheet 1 Vent Piping from Outside Tanks 620F05PP03, Waterglass Ammonia Scrubber Ventilation Plan, Pipe Rack Rev. 02 Sheet 1 N/A First Floor Area Designations IFBA and ERBIA Rev. P1 Engineering Integrated Safety Analysis Summary - Columbia Fuel Rev. 16 Evaluations Fabrication Facility CSE-7-A Criticality Safety evaluation for the Solvent Extraction System Rev. 14 CSE-99-M Criticality Safety Evaluation for the CFFF Design Basis Rev. 4 Seismic Event FHA-13-001 Fire Hazards Analysis, Appendix Yard-01, UF6 Storage Pad Rev. 2 FHA-13-001, Fire Hazard Analysis for Columbia Fuel Fabrication Facility Rev. 1 Appendices CHEM-02 and CHEM-12 Miscellaneous LTR-RAC-22-04 Westinghouse 10 CFR 70.72 Facility Change Report 01/27/2022 PM21018 Preventive Maintenance - Concrete Barriers for SBG Fuel Completed Tanks on 8/30/2021 PM21026 Preventive Maintenance - Visual Mechanical Integrity Completed Inspection on Double Walled Fuel Oil Tank on 4/6/2022 Procedures CA-004 Records Management Rev. 24 COP-830110 SOLX & Product Concentrator System 1 - Startup & Rev. 45 33

Inspection Type Designation Description or Title Revision or Procedure Date Operation COP-830111 SOLX & Product Concentrator System 2 - Startup & Rev. 34 Operation MCP-202245 Standby Generator Fuel Filling Rev. 2 MCP-203530 Hydrogen Excess Flow Valve Bypass Management Rev. 0 QA-006 Computer Software Quality Assurance Rev. 52 QA-007 Programmable Logic Controller Software Quality Assurance Rev. 24 QAF-006-01 Software Verification and Validation Decision Rev. 22 RA-106 Regulatory Component Audits at the Columbia Fuel Rev. 42 Fabrication Facility TA-500-10 Configuration Management Risk Assessment Board Meeting Rev. 4 34