ML23030B617
| ML23030B617 | |
| Person / Time | |
|---|---|
| Site: | Framatome ANP Richland |
| Issue date: | 01/31/2023 |
| From: | Eric Michel NRC/RGN-II/DFFI/FFB2 |
| To: | Stephens L Framatome |
| References | |
| EN 55897, EN 56173 IR 2022004 | |
| Download: ML23030B617 (24) | |
Text
January 31, 2023 EN 55897 EN 56173 Lance Stephens Site Manager Framatome Inc.
2101 Horn Rapids Road Richland, WA 99354
SUBJECT:
FRAMATOME-RICHLAND - CORE INSPECTION REPORT 07001257/2022004
Dear Lance Stephens:
This letter refers to the Nuclear Regulatory Commission (NRC) inspection activities conducted from October 1 to December 31, 2022, for the Framatome-Richland fuel facility. On October 24th, November 14th, and November 28th, the results of this inspection were discussed with you and other members of your staff. The results of this inspection are documented in the enclosed report.
No NRC-identified or self-revealing violations were identified during this inspection.
A licensee-identified violation which was determined to be a Severity Level IV violation is documented in this report. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy. The NCV is described in the subject inspection report.
If you contest the violation or the significance or severity of the violation 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: (1) the Regional Administrator, Region II; (2) the Director, Office of Enforcement; United States Nuclear Regulatory Commission, Washington, DC 20555-0001.
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. To the extent possible, your response should not include any personal privacy or proprietary information so that it can be made available to the public without redaction.
L. Stephens 2 Sincerely, Signed by Michel, Eric on 01/31/23 Eric C. Michel, Chief Projects Branch 2 Division of Fuel Facility Inspection Docket No. 07001257 License No. SNM-1227
Enclosure:
As stated cc w/ encl: Distribution via LISTSERV
ML23030B617 x Non-Sensitive x Publicly Available x SUNSI Review Sensitive Non-Publicly Available OFFICE RII/DFFI/ PB2 RII/DFFI/ PB2 RII/DFFI/PB2 NAME C. Taylor G. Goff E. Michel DATE 1/30/23 1/30/23 1/31/23 U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number: 07001257 License Number: SNM-1227 Report Number: 07001257/2022004 Enterprise Identifier: I-2022-004-0062 Licensee: Framatome Inc.
Facility: Framatome-Richland Location: Richland, WA Inspection Dates: October 24 through 27, 2022 November 14 through 17, 2022 November 28 through December 1, 2022 Inspectors: L. Cooke, Fuel Facility Inspector G. Goff, Fuel Facility Inspector N. Peterka, Fuel Facility Inspector T. Sippel, (Senior) Sr. Fuel Facility Inspector C. Taylor, Sr. Fuel Facility Project 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 a core inspection at Framatome-Richland, in accordance with the fuel cycle facility inspection program. This is the NRCs program for overseeing the safe operation of licensed fuel cycle facilities. Refer to https://www.nrc.gov/materials/fuel-cycle-fac.html for more information.
List of Violations Failure to Follow Free Release Limit for Hazardous Waste Shipment Significance Report Section Severity Level IV 86740 NCV 07001257/2022004-01 Open/Closed The inspector's review of Written Event Report (WER) 07001257/2022-003-00, "Failure to Follow Free Release Limit for Hazardous Waste Shipment" resulted in a licensee-identified, SL-IV, non-cited violation (NCV) of Condition S-1 of the license and 10 Code of Federal Regulation (CFR) 71.5, "Transportation of Licensed Material."
Additional Tracking Items Type Issue Number Title Report Section Status WER 07001257/2022-003-00 Concurrent Report 86740 Closed Inadvertent Radwaste Shipment (EN 56173)
WER 07001257/2022-002-00 Gamma Monitors Non- 88020 Closed Functional (EN 55897)
URI 07001257/2022-004-02 MURS Furnace Electrical 88072 Open Hazard 2
PLANT STATUS The Framatome facility converts uranium hexafluoride (UF6) into uranium dioxide (UO2) for the fabrication of low-enriched fuel assemblies used in commercial light water reactors. During the inspection period, normal production activities were ongoing.
INSPECTION SCOPES Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Inspections were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2600, Fuel Cycle Facility Operational Safety and Safeguards Inspection Program. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
SAFETY OPERATIONS 88015 - Nuclear Criticality Safety The inspectors evaluated selected aspects of the licensees Nuclear Criticality Safety program to verify compliance with selected portions of 10 Code of Federal Regulation (CFR) 70, including 70.61, 70.62, and Appendix A, Chapter 5, Nuclear Criticality Safety, of the facilitys license application, and applicable licensee procedures.
Criticality Analysis (IP Section 02.01)
The inspectors interviewed licensee staff and reviewed nuclear criticality safety analyses (NCSAs), and associated assumptions and calculations, to verify compliance with 10 CFR 70 and applicable sections of the license application, including portions of 3.1.4, 3.1.5, 3.1.6, 5.3.4, and 5.4. Specifically, the inspectors interviewed licensee staff, walked down systems, and reviewed the following NCSAs:
E04-NCSA-150, "Miscellaneous Uranium Recovery System (MURS)," Version 25, including the review of the what-if analysis, double contingency analysis, items relied on for safety (IROFS) control tables, SCALE computer models, and accident sequences 1.2, 4.1, and 5.2 E04-NCSA-350, "I3A Storage Facility," Version 15, including review of what-if analysis, normal, credible abnormal, and non-credible accident sequences E04-NCSA-960, "HVAC Building Exhaust," Version 41, including the review of what-if analysis, normal, credible abnormal, and non-credible accident sequences and the IROFS that were established to prevent criticality 3
Criticality Implementation (IP Section 02.02)
The inspectors selected engineered and administrative controls from the licensees integrated safety analysis (ISA) summary to verify proper implementation through a review of process and system descriptions, plant walkdowns, and interviews to verify compliance with 10 CFR 70 and applicable sections of the license application, including portions of 11.2.2. Specifically, the inspectors interviewed licensee staff and reviewed the following controls, and their management measures, associated with the NCSAs listed above:
IROFS 6108.00, "Moderation/Geometry Control by Operator Surveillance," an administrative control to detect small spills and leaks of licensed material IROFS 6522, "Ultrasonic Cleaner Overflow Drain," a passive engineering control to prevent the buildup of liquids and solids - reviewed field verification measurements IROFS 1402, 1402.1, "SBC Overweight Protection by NIMS Scale Mass Limit," an active engineered control to prevent overfilling of containers -
reviewed most recent functional test documentation IROFS 4520, 4528, "U3O8 Primary HEPA Filter Change-Out - Fissile Mass Loading," engineered control to limit fissile material accumulation - reviewed most recent filter change out documentation and weight Criticality Operational Oversight (IP Section 02.03)
The inspectors assessed the NCS staffs oversight of plant operators, procedures, and operations of systems involving special nuclear material to verify compliance with 10 CFR 70 and applicable sections of the license application, including portions of 5.3.10, 5.3.11, and 5.5. Specifically, the inspectors performed the following activities:
observed a licensee nuclear criticality safety (NCS) engineer perform an audit of operations in the MURS area reviewed the current audit schedule and multiple monthly NCS audits interviewed MURS operator on the IROFS in the area and the associated operating procedures Criticality Programmatic Oversight (IP Section 02.04)
The inspectors reviewed NCS program procedures and NCS staff qualifications to verify compliance with 10 CFR 70 and applicable sections of the license application, including portions of 2.2.5.1. Specifically, the inspectors:
reviewed qualification records and training requirements for criticality safety analysts reviewed a recently revised procedure E04-NCSS-G01, "NCS Guide Rules and Generic Program Requirements," Version 24 interviewed NCS staff concerning the NCS review of changes, including changes to operating procedures that may affect NCS, and changes to the facility 4
Criticality Incident Response and Corrective Action (IP Section 02.05)
The inspectors reviewed the licensees criticality accident alarm system (CAAS) and implementation of the corrective action program (CAP) to verify compliance with 10 CFR 70 and applicable sections of the license application, including Section 5.5. Specifically, the inspectors performed the following activities:
reviewed selected issues entered in the CAP pertaining to IROFS and audit findings reviewed selected 2021 and 2022 surveillance and maintenance records for the CAAS reviewed revised engineering analysis, E04-09-001, "HRR Criticality Accident Alarm System Coverage Demonstration," Version 7 88020 - Operational Safety The inspectors evaluated selected aspects of the licensees Operational Safety program to verify compliance with selected portions of 10 CFR 70, including 70.61, 70.62, and Chapter 11, Management Measures, of the facilitys license application, and applicable licensee procedures.
Identification of Safety Controls and Related Programs (IP Section 02.01)
The inspectors selected specific process areas for inspection based on the safety basis information of the facility, the risk/safety significance of the process areas, the description of plant changes submitted to the NRC, and past plant performance documentation. For the process areas of interest, the inspectors selected a sample of accident sequences in nuclear criticality safety, radiation safety, and chemical safety based on the information provided in the ISA summary. The inspectors conducted a tour of the Dry Conversion Facility (DCF) and Pelleting. The process areas selected for review are listed below:
Dry Conversion Vaporization (System 810)
Dry Conversion Powder Production (System 820)
Liquid Effluent and HF Recovery (System 840)
Review of Safety Controls and Related Programs (IP Section 02.02)
The inspectors reviewed information related to administrative, engineered, and passive safety controls or items relied on for safety (IROFS) in the process areas selected above, including the identification of the licensees assumptions and bounding cases as they apply to each of the selected accident sequences, safety controls, or IROFS. This review was performed to verify that the safety controls or IROFS were available and reliable to perform their intended safety functions and that the design basis assumptions were reflected in the actual conditions in the field. The specific safety controls selected for review are listed below:
IROFS 813 and IROFS 816, administrative controls, required actions to take in response to a chemical releases and exposures used for chemical safety 5
IROFS 905, passive engineered control, autoclaves shall be built, tested, and certified in accordance with the American Society of Mechanical Engineers (ASME) Boiling and Pressure Vessel Code IROFS 906, administrative control, a limitation on cylinder movement used for chemical safety IROFS 924, active engineered control, a uranium hexafluoride (UF6) cylinder high pressure interlock used for chemical safety IROFS 1002, administrative control, a mass control used for nuclear criticality safety IROFS 1005, IROFS 1006, IROFS 1007, active engineered controls, temperature sensors and interlocks used for nuclear criticality safety IROFS 1014, active engineered control, a moisture sensor and alarm used for nuclear criticality safety IROFS 1108 and IROFS 1109, passive engineered controls, moderation barriers used for nuclear criticality safety IROFS 1205, IROFS 1205.10, IROFS 1206, and IROFS 1206.10, passive engineered controls, filters used for nuclear criticality safety IROFS 1207, active engineered control, a uranium monitor and interlock used for nuclear criticality safety IROFS 1226, administrative control, a required operator check on water seals used for chemical safety IROFS 2215, administrative control, personnel protective equipment (PPE) requirements used for chemical safety Implementation of Safety Controls (IP Section 02.03)
For the selected safety controls listed above, the inspectors reviewed management measures to verify proper implementation in accordance with 10 CFR 70 and applicable sections of the license application. This review was performed to verify that selected safety controls or IROFS were present, available, and reliable to perform their safety function and that the design basis assumptions were reflected in the actual conditions in the field. The inspectors conducted the following activities to verify the implementation of selected safety controls:
performed walkdowns to verify the presence of the IROFS 1226 water seals, reviewed control room logs and interviewed operators about the IROFS performed walkdowns to verify the presence of the IROFS 905 and the ASME pressure vessel name plate and certification on the autoclaves performed walkdowns to verify the presence of the IROFS 1014, moisture sensor and alarm, observed integrity of the double roof, and interviewed control room operators on how they would respond to such an alarm reviewed various standard operating procedures (SOPs), including SOP-40209, for inclusion of IROFS 2215 PPE requirements reviewed NCSP-820-001, "Reactor Bed Loading & Calciner Recycle Station,"
Version 1.0 reviewed NCSP-820-002, "Calciner Product Download Hood - DCF," Version 2.0, and walked down the product download hood and interviewed an area operator 6
Safety Control Support Programs (IP Section 02.04)
The inspectors assessed additional management measures that support the availability and reliability of the selected safety controls to verify these were implemented in accordance with 10 CFR 70 and applicable sections of the license application. Additionally, the inspectors followed-up on written event report (WER) 07001257/2022-002-00, "Gamma Monitors Non-Functional (event number (EN) 55897)." Specifically, the inspectors conducted the following:
reviewed work orders (WOs) and maintenance procedures documenting completion of IROFS tests, including:
o WOs 13543211, 13543213, 13568339 and 13568341; for IROFS 1005 and 1006 o WOs 13561126 and 13568343; for IROFS 1007 o C810P003, "UF6 Cylinder Heat Interlocks 6Mo OPDC," Rev. 15; for IROFS 924 reviewed CAP entries and associated documents related to failure and degradation records for IROFS, including CR-2021-2336, CR-2021-2665, CR-2022-0134, and CR-2022-1897 reviewed Internal Audit Report 21-74, Rev. 0 reviewed HRR-CMO-000011, "UCAR Operations - Dry Conversion Control Room," Rev. 5; an on-the-job training checklist for DCF control room operators reviewed multiple records of Dry Conversion operator training including training on IROFS and applicable procedures HRR-CMO-000014, "UCAR Operations - Dry Conversion UF6 Handler," Rev.
5; an on-the-job training checklist for UF6 cylinder handlers interviewed DCF control room operators concerning the IROFS and process areas described above, including alarm indications, required operator actions, off-normal conditions and shift checks observed licensee maintenance planning meetings observed licensee plan of the day meetings RADIOLOGICAL CONTROLS 86740 - Inspection of Transportation Activities The inspectors followed-up on WER 07001257/2022-003-00, Failure to Follow Free Release Limit for Hazardous Waste Shipment, (EN 56173) to evaluate if the licensees response was in accordance with 71.95 (transportation events) and 20.2201 and 20.2202 (radiological and environmental events).
Inspection of Transportation Activities On September 22, 2022, the licensee provided concurrent notification to the NRC that 18.3 grams of depleted uranium was inadvertently free released and transported to an unlicensed offsite waste disposal facility. The licensee was unable to retrieve the 18.3 grams of depleted uranium as it had been processed for disposal. The depleted uranium potential safety and environmental impacts were of very low safety 7
significance. The dose to the public was below the radiation public dose limit of 100 mrem/year and this issue did not result in an actual radiological consequence.
Specifically, the inspectors conducted the following activities:
reviewed EN 56173, "Concurrent Report for Shipment of Undeclared Hazardous Waste."
reviewed CAP entries, associated documents and corrective actions related to the release of 18.3 grams of depleted uranium as an undeclared hazardous waste, including CR-2022-2339 reviewed Apparent Cause Analysis for CR 2022-2339, dated 10/28/2022 reviewed Job Order 4891208, Clean Earth Packing Inventory List reviewed SOP 40053, Release of Items from Contaminated Areas, Version 13 reviewed Standard Work Instruction (SWI), IsoCart Sample Analysis, Version 6.0 reviewed survey results: Sample ISO6565 & ISO6565A-1724 for Lab Drums, dated 5/17/2022, VSDS Itemized Survey Report, I-20221003-2 for ELO Lab 39 Equipment, dated 10/3/2022 reviewed Summit Environmental Technologies Analytical Laboratories Report, dated 10/26/2022 reviewed Job Number 240-175216-1, Eurofins Environmental Analytical Report, dated 11/21/2022 interviewed transportation specialist and manager regarding status of the remaining open corrective actions for the incident The inspectors identified a non-cited violation associated with this incident. See the "Inspectors Results" section of this inspection report for details. The licensee submitted a 60-day written report (ML22341A156) in accordance with 10 CFR 70.74(b).
FACILITY SUPPORT 88050 - Emergency Preparedness The inspectors evaluated selected aspects of the licensees emergency preparedness program to determine whether the program is maintained as required by the Emergency Plan, the license and license application, and NRC requirements in 10 CFR Part 70.
Emergency Preparedness Program Review and Implementation (IP Section 02.01)
The inspectors selected the following elements that support the implementation of the licensees emergency preparedness program to verify compliance with 10 CFR 70.22(i)(3),
Chapter 8 of the license application, and the Emergency Plan. Specifically, the inspectors conducted the following inspection activities:
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reviewed changes to the emergency preparedness program, including annual updates to the Emergency Plan reviewed revisions to the Emergency Plan Implementing Procedures (EPIP) that were updated since the last NRC inspection, including revised EPIPs focused on Criticality Alarm Actions for Interim Plant Emergency Director on Backshift, Weekends, Holidays, (E08-03-8.13A), and Incident Commander (E08-03-8.13B) reviewed training and staffing of the emergency preparedness organization including minimum staffing requirements and qualifications for new members of the Plant Emergency Response Team (PERT) and Plant Emergency Response Team Management (PERTM) reviewed training records and conducted interviews of select members of the PERT and PERTM, including the Emergency Director, Interim Emergency Director, Incident Commander, Nuclear Safety Advisor for Criticality review current Memorandums of Understanding (MOU) agreements and reviewed training offered to offsite support agencies visited and interviewed off site support agencies that included the local hospital and local fire department conducted interviews related to the 2022 biennial emergency exercise and reviewed records associated with the most recent criticality evacuation and accountability drill conducted interviews, reviewed records, and conducted plant walkdowns of emergency equipment and storage and emergency facilities that included the Emergency Control Center, Alternate Emergency Control Center, staging areas, select assembly points, and emergency vehicles Identification and Resolution of Problems (IP Section 02.02)
The inspectors reviewed the licensees identification and resolution of emergency preparedness issues to verify compliance with the license requirements. Specifically, the inspectors reviewed the following corrective action program entries, audits, and self-assessments:
reviewed the FRA_D3SEP_IG22_031_IR, "Richland Horn Rapids Road (HRR) Facility 2022 Triennial Emergency Preparedness Assessment, dated June 20 - 23, 2022,"
reviewed "US Fuel Internal Audit Report (22:55)," dated July 6 - 8, 2022 reviewed "US Fuel Internal Audit Report (21:56)," dated October 6 -19, 2021 reviewed corrective actions as documented in the documents reviewed section of this inspection report Event Review (IP Section 02.03)
The inspectors reviewed the licensees safety-significant and internal events related to emergency preparedness to verify compliance with 10 CFR 70.22(i)(3), Chapter 8 of the license application, and the Emergency Plan. Specifically, the inspectors performed the following activities:
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reviewed implementation of the Emergency Plan associated with the following internal, nonreportable activations and temporary compensatory measures:
o "Fire Alarm in ELO Building," dated July 14, 2022 o "Fire Alarm in MERF," dated September 10, 2021 o "Personal Medical Issue in Carpenter Shop," dated October 20, 2020 88072 - Plant Modifications (Triennial)
The inspectors conducted an extensive review into the licensees configuration management system for plant modifications to ensure that safety-related systems and components (i.e., IROFS or credited safety controls) could adequately perform their intended safety function and that system changes had not adversely impacted plant safety and operability. The inspectors review focused on verifying compliance with the applicable requirements in 10 CFR 70 and the License Application, Chapter 11, Management Measures.
Selection of Modifications (IP Section 02.01)
The inspection team reviewed licensing documents to discuss plant modifications in risk-significant areas/processes with the licensee. The inspectors selected the following process for an in-depth review of historical modifications identified as Engineering Change Notices (ECNs):
Miscellaneous Uranium Recovery System (MURS)
ECN 1424, MURS New System ECN 4425, Pumps Upgrade MURS Facility ECN 5325, MURS PLC Replacement ECN 5358, MURS Oxidation Pan Furnace Mod.
ECN 5368, MURS PH & U Upgrade ECN 5391, MURS Facility Strainer Modification ECN 5460, MURS Oxidation Furnace Mods ECN 5614, MURS 703 Pumpout Line Modification ECN 5971, Isolation Valves Ion Exchange Columns MURS Facility ECN 6835, MURS Acid Cleaning Modification ECN 6988, Replace MURS Facility 704 Tanks ECN 6989, Modify MURS Facility Furnace Tray ECN 7505, MURS Ion Exchange Column Pipe Change ECN 7790, MURS Facility 703 Pump Modification ECN 7831, Isolate the MURS IX Columns ECN 7838, MURS 703 Tank Piping Removal ECN 7883, MURS IX System Changes ECN 8911, Demo and Prep ECN 8931, ADU IX Installation Design Process Review (IP Section 02.02)
For the selected modifications listed above, the inspectors reviewed the design process to verify the licensee followed the applicable configuration management requirements in the license application and 10 CFR 70. Specifically, the inspectors conducted the inspection activities listed below:
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interviewed licensee staff, performed walkdowns, and reviewed change packages and supporting documentation reviewed the ISA Summary and safety program information impacted by the modifications interviewed licensee staff and reviewed documentation to verify the licensee applied management measures to the IROFS affected by the modifications reviewed change management packages and supporting documentation and subsequently performed walkdowns to verify that safety systems and components impacted by the modification, including interactions with other systems, would still perform their intended safety function as described in the ISA and safety program documentation reviewed CAP documents for plant modification issues to verify compliance with the CAP activities described in the license application System Condition and Capability Review (IP Section 02.03)
For the selected modifications, the inspectors reviewed the system condition and tested capability to verify they were consistent with the applicable design requirements and licensing basis. Specifically, the inspectors conducted the inspection activities listed below:
reviewed ISA Summary, Section 9.6., "Miscellaneous Uranium Recovery Systems (MURS), (System 150) to determine if the licensee was maintaining the ISA Summary consistent with the requirements of 10 CFR 70.72 conducted walkdowns with MURS process engineering personnel and reviewed records to verify that the as-built configuration of the system/equipment was consistent with the process safety information and ISA Summary changes contained in the plant modification packages conducted interviews, records reviews, and plant walkdowns to verify whether management measures were properly implemented to ensure that IROFS or other safety controls were available and reliable to perform their function when needed; specifically, the inspectors reviewed the calibration dates and preventative maintenance procedures for the IROFS Scale Serial Station 099 UO2 conducted interviews and records reviews to verify that IROFS administrative controls that involve operator action could be accomplished as stated in the licensees ISA; specifically, the inspectors reviewed Work Order 13575779, "Equipment No. (US19410-60) Weight Scale Serial Station 099" calibration results dated October 15, 2022, for IROFS 6502 to verify calibration was performed and results were within acceptable limits conducted interviews, records reviews, and plant walkdowns to verify IROFS such gamma monitors, pH monitors, and uranium monitors were available, capable, and reliable to perform their function when needed; specifically, the inspectors reviewed the calibration dates and preventative maintenance procedures for the ion exchange (IX) columns 11
Post-Modification Testing (IP Section 02.04)
For the selected modifications, the inspectors interviewed licensee staff and reviewed post-modification testing records to determine whether the plant was in a safe configuration during post-modification testing. The inspectors reviewed the following post-modification tests to determine whether post-modification testing ensured adequate implementation of the design and safety system functionality.
MURS Furnace and Instrumentation reviewed Work Order C05325C, Equipment Acceptance Test Procedure/Results, ATP 96-007, MURS PLC Replacement" reviewed Work Order EO5460S, MURS Oxidation Furnace" reviewed "Project Information & Design/Drafting Request, ECN 5358" reviewed Equipment Acceptance Test Procedure, (EXXON Nuclear Company)"
reviewed Building Wall Penetration" reviewed Scope of Work & Work Order E06988C, Remove MURS Tank 704 reviewed Criticality As-Built Check List (EMF-1955), MURS ADU Furnace Oxidation Tray Loading," Rev. 0 MURS/ADU Line 2 - Ion Exchange Operation and Regeneration reviewed Work Order C080P024, "IX Pre Filter 3MO OPCH" reviewed Work Order C163P103 for IROFS 2317 reviewed Work Order C080P025 for IROFS 2318 Documentation Review (IP Section 02.05)
The inspectors reviewed a sample of plant documents impacted by the modifications selected for review to verify the licensee had either updated or was in the process of updating such documents to reflect the modifications in accordance with the license application requirements and 10 CFR 70.72. The inspection sample included:
reviewed CSA 066, 826, UF6 Conversion MURS Overflow Tank 702, Rev.1, for replacement of unfavorable geometry tank and equipment review reviewed standard work instruction, SWI-40245A, MURS Furnace Operations, Version 7, to verify process described in procedure was performed in the field reviewed piping & instrumentation diagram (P&ID) "CSA-611,150: MISC.
Uranium Recovery System P&ID," Rev. 7 to verify project modification was updated for the new MURS tray system reviewed the following procedures:
o MCP-30016, "Management Control Procedure," Version 29 o MCP-31044, "Control Design Description (System 150)," Version 3.0 o SOP-40245, "MURS Furnace Operations," Version 7.0 reviewed CSA-611080:
o ADU IX Column V-167 P&ID o ADU IX Column V-168 P&ID o ADU IX Column V-169 P&ID o ADU Process Uranium Recovery P&ID 12
o Line 2 Uranium Recovery P&ID INSPECTION RESULTS Failure to Follow Free Release Limit for Hazardous Waste Shipment Severity Report Section Severity Level IV 86740 NCV 07001257/2022004-01 Open/Closed The inspector's review of Written Event Report (WER) 07001257/2022-003-00, "Failure to Follow Free Release Limit for Hazardous Waste Shipment" resulted in a licensee-identified, SL-IV, non-cited violation (NCV) of Condition S-1 of the license and 10 Code of Federal Regulation (CFR) 71.5, "Transportation of Licensed Material."
Description:
Special Nuclear Materials License 1227, Condition S-1, states in part, that the licensee shall conduct activities in accordance with the statements, representations, and conditions in the license application. Chapter 1 of the license application Section 1.2.4.3, Waste Disposal, states, Pursuant to 10 CFR 20.2002, disposal of solid waste material containing uranium at 30 picoCuries/gram (piC/gm) or less to other than a licensed waste disposal facility is authorized. The low enriched uranium shall not exceed 30 pCi/gm of dry solid waste material.
Contrary to the above, on August 5, 2022, the licensee failed to properly dispose of dry solid waste material containing uranium at greater than 30 pCi/gm by allowing a shipment to an unlicensed, offsite waste disposal facility. Specifically, the dry solid waste material contained 18.3 grams of depleted uranium. This violation is identified as a NCV 70001227/2022004-01, Failure to Follow Free Release Criteria for Shipment of Hazardous Waste Material.
The depleted uranium potential safety and environmental impacts were deemed to be of very low safety significance. The dose to the public was below the radiation public dose limit of 100 mrem/year and this issue did not result in actual radiological consequences.
On 10/20/22, the licensee provided a 30-day written report to the Department of Transportation (DOT) and concurrent report to the NRC under the provisions of 10 CFR 70.50(c)(1)(viii). The licensee subsequently submitted a 60-day written report, ADAMS Accession Number (ML22341A156) to the NRC in accordance with 10 CFR 70.74 (b).
Corrective Action
References:
The licensee entered this issue into its corrective action program as Condition Report 2022-2339.
Analysis: NA Enforcement:
Severity: This violation was determined to be a SL- IV violation consistent with Example 6.3.d.3 of the NRC Enforcement Policy. WER 07001257/2022-003-00, "Failure to Follow Free Release Limit for Hazardous Waste Shipment (EN56173)," is closed to this NCV.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
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WER Gamma Monitors Non-Functional (EN 55897) 88020 (Discussed) WER 07001257/2022-002-00
Description:
On May 12, 2022, the licensee identified that two gamma detectors in the Ammonia Recovery Facility (ARF) were not working. The two gamma detectors were credited as IROFS 2309 and 2310, which were used to monitor for gradual long-term accumulations of uranium in unfavorable geometry sand filter tank V680. This event was previously been inspected by the NRC during the week of May 23, 2022, as documented in NRC Inspection Report 07001257/2022002 (ML22201A535).
The inspectors interviewed licensee engineers, reviewed the licensee's Apparent Cause Analysis for CR-2022-1299 and CR-2022-1300, the licensee's 60-day written report (ML22192A127), and the latest version of E04-NCSA-163 to verify that the applicable accident sequence remained highly unlikely while the gamma monitors were failed.
Therefore, WER 07001257/2022-002-00, "Gamma Monitors Non-Functional (EN 55897)" is closed.
Unresolved Item MURS Furnace Electrical Hazard 88072 (Open) URI 07001257/2022004-02
Description:
On February 17, 2021, during maintenance of the Miscellaneous Uranium Recovery System (MURS) furnace heaters, a licensee electrician identified an electrical hazard where an operator could be electrocuted if physical contact were to be made between the 480-volt heating elements and the boat moving tool (a metal rod that operators use to move boats within the furnace), because the electrically powered heating element did not de-energize when the furnace door was opened. An interlock meant to de-energize the heating elements upon opening of the furnace door had failed at an unknown date.
Planned Closure Actions: The NRC is reviewing the MURS furnace electrical hazard issue with internal subject matter experts to determine whether a violation of NRC requirements exists.
Licensee Actions: Upon discovery, the licensee implemented the immediate corrective action to have operators wear electrically rated gloves. On June 17th, 2021, the licensee completed the long-term corrective action to install a failsafe interlock that shuts power off to the heating elements when the furnace door is opened, at which point gloves were no longer required.
Corrective Action
References:
The licensee entered this issue into its corrective action program as CR-2021-0381 EXIT MEETINGS AND DEBRIEFS The inspectors verified no proprietary information was retained or documented in this report.
On October 27, November 17, and December 1, 2022, the inspectors presented the inspection results to Lance Stephens and other members of the licensee staff.
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DOCUMENTS REVIEWED Inspection Type Designation Description or Title Revision, Procedure Version, or Date 86740 Corrective Action CR 2022-2339 Reportability Evaluation - Uniform Hazardous Waste 9/23/2022 Documents Shipment 000386771 CR 2022-2339 US Fuel Apparent Cause Analysis Miscellaneous 240-175216-1 Eurofins Environmental Testing- Analytical Report 10/21/2022 Form DOT F 5800.1 Hazardous Material Incident Report 10/20/2022 (01-2004)
Procedures FRM -20287 Waste/Hazardous Material Shipment Inspection Form Version 4.0 SOP-40053 Release of Items from Contaminated Areas Version 13.0 SOP-40389 Preparing Low Level Radioactive Waste (LLRW), Special, Version 9.0 Mixed and Hazardous Waste Material Shipments SWI - 50016 G ISoCart Sample Analysis Version 6.0 Radiation Isotopic V4.1 - 1724 Lab Drum 05/12/2022 Surveys ISO6565 Isotopic V4.1 - 1724 Lab Drum 05/17/2022 ISO6565A Isotopic V4.1- 1723 Lab Drum 05/12/2022 ISO6566 Survey - I-20221003- VSDS Itemize Survey Report 10/03/2022 2
Shipping Records 000444846 Uniform Hazardous Waste Manifest 10/03/2022 000444935 Uniform Hazardous Waste Manifest 10/13/2022 4891208 Clean Earth - Packing Inventory Slip 08/05/2022 Work Orders 22092026 Summit Environmental Technologies Analytical Report 09/30/2022 88015 Corrective Action CR 2022-1726, NCS Related Condition Reports Various Documents 2022-1897, 2022-1924, 2022-2106, 2022-2234 Drawings CSA-611150 Miscellaneous Uranium Recovery System P&ID Revision 13 CSA-614,511 Service Equipment Ultrasonic Cleaning Tank Revision 3 Engineering E04-09-001 HRR Criticality Accident Alarm System Coverage Version 7 Evaluations Demonstration 15
Inspection Type Designation Description or Title Revision, Procedure Version, or Date E04-09-002 Criticality Accident Alarm System Coverage Analysis for Version 3 FANP Richland E04-NCSA-150 Miscellaneous Uranium Recovery System (MURS) Version 25 E04-NCSA-350 I3A Storage Facility Version 0 E04-NCSA-480 U02 Rod Transport and Storage Version 15 E04-NCSA-810 Dry Conversion Vaporization System Version 16 E04-NCSA-960 HVAC Exhaust Systems Version 41 E04-NCSS-G07 Building and Facilities NCS Design Requirements Version 12 Including Initial Conditions and Bounding Assumptions Procedures E04-NCSS-G01 NCS Guide Rules and Generic Program Requirements Version 24 E04-NCSS-G08 Plant Wide Chemical Safety IROFS Version 13 E04-NCSS-G92 Moderation Control Version 20 SOP-40821 Instruction Manual HEPA and Prefilter Change-outs Version 15 Self- E04-07-202205 NCS Audit/Inspection Report - May 2022 Version 1 Assessments E04-07-202206 NCS Audit/Inspection Report - June 2022 Version 1 E04-07-202207 NCS Audit/Inspection Report - July 2022 Version 1 E04-07-202208 NCS Audit/Inspection Report - August 2022 Version 1 E04-07-202209 NCS Audit/Inspection Report - September 2022 Version 1 E04-07-202210 NCS Audit/Inspection Report - October 2022 Version 1 Work Orders 13547865 C960P029 Ductwork Insp Fiss Mat 1Y OPDC 03/03/2022 13547922 C100P001 L2 Overflow / Vents 12MO PF 03/17/2022 13556249 CG78P002 Scales Accountability 12MO RE 05/05/2022 13564686 C960P034 K37-17-7 HEPA Replace 6MO AB 07/26/2022 13571765 C960P001 HVAC K3 EXH SYS UO2 3MO OPCR 09/29/2022 13571768 C960P003 Duct Inspection 3MO OPCH 10/05/2022 13571839 C960P002 Duct Inspection 3MO OPCH 10/05/2022 13575853 C960P004 Duct Inspection 3MO OPCR 10/24/2022 13576135 C960P026 Duct Inspection 12MO OPCR 10/26/2022 88020 Corrective Action CR-2021-2336, CR- Operational Safety Related CR Entries Various Documents 2021-2665, CR- Dates 2021-2864 Corrective Action CR-2022-3093 12/01/2022 16
Inspection Type Designation Description or Title Revision, Procedure Version, or Date Documents Resulting from Inspection Drawings 9376-012-01-0-00 Filter cartridge 04/05/2021 Engineering E04-NCSA-163 Industrial Waste Water Treatment Facilities Version 35.0 Evaluations E04-NCSA-820 Dry Conversion Powder Production Process Version 19.0 E04-NCSA-840 Dry Conversion Liquid Effluent and HF Recovery Version 9.0 E04-NCSS-G08 Plant Wide Chemical Safety IROFS Version 13.0 E15-01-2.10 Part 2 - Chapter 10 - Dry Conversion Facility Version 19.0 Miscellaneous HRR-CMO-000011 On The Job (OJT) Training Checklist Revision 5 UCAR Operations - Dry Conversion Control Room HRR-CMO-000014 UCAR Operations - Dry Conversion UF6 Handler Revision 005 HRR-CMO-000034 Skills Evaluation 05/22/2018 Chemical Operations - Dry Conversion Control Room Procedures ADM-00008 Control of Operator Aids in Richland Operations Version 9.0 C810P003 UF6 Cylinder Heat Interlocks 6 Mo OPDC Revision 15 E12-03-058 Incident Investigation/Corrective Action Audit 05/05/2022 MCP-30052 Bulk Chemical Loading & Unloading Version 10.0 MCP-30070 PPE - Dry Conversion Facility Version 9.0 MCP-30324 Richland Procedure Writers Guide Version 15.0 SOP-40209 Dry Conversion Facility Vaporization Room, Process & Version 9.0 Powder Prep SOP-40285 Dry Conversion Facility - Preparation and Heatup Version 15.3 SOP-40286 Dry Conversion Facility - Process Startup Version 11.0 SOP-40287 Dry Conversion Facility - Steady State Operation Version 23.0 SOP-40288 Dry Conversion Facility - UF6 Cylinder Heel Removal Version 6.0 Vacuum Pump Operation SOP-40292 Dry Conversion Facility - Preparing and Removing UF6 Version 22.0 Cylinders SOP-40293 Dry Conversion Facility - Process Offgas Version 11.1 SOP-40297 Dry Conversion Facility - UF6 General Information Version 11.0 SOP-40299 Dry Conversion Facility - Reactor Bed Loading and Version 6.0 17
Inspection Type Designation Description or Title Revision, Procedure Version, or Date Downloading SOP-41068 Training and Qualification Version 3.1 Self- Internal Audit Report Internal Audit Report Revision 0 Assessments 21-74 Work Orders 13526565 C820P003-0001 HEAT INTERLOCKS Y2 OPDC 03/07/2022 13526566 C820P003-0001 INTERLOCK CHECK L1 Y2 OPDC 03/07/2022 13530370 C810P009-0006 DC AUTOCLAVE 6MO MWHZ 11/15/2021 13543211 C820P003-0002 Interlock Check L2 Y2 OPDC 05/16/2022 13543212 C820-P004-0002 VX-203 INTRLK R GS Y2 OPDC 05/16/2022 13543213 C820P005-0002 Interlock Check L2 Y2 OPDC 05/16/2022 13543214 C820P006-0002 INTRLK Reactin Gas Y2 OPDC 05/16/2022 13551122 C820P004-0003 VX-203 INTRLK R GS Y2 OPDC 06/20/2022 13552142 C821I001 Thermocouple Reac 6Mo IN 04/22/2022 13561126 C820P007-0003 PLC SFTY INTRLK L3 6 OPDC 04/22/2022 13561128 C820P008-0003 CALCNR RG INTERLK Y2 OPDC 06/20/2022 13561129 C820P011-0003 SHUTOFF INTERLOCK Y2 OPDC 06/20/2022 13568339 C820P003-0002 Interlock Check L2 Y2 OPDC 09/14/2022 13568340 C820P004-0002 VX-203 INTRLK R GS Y2 OPDC 09/13/2022 13568341 C820P005-0002 Interlock Check L2 Y2 OPDC 09/14/2022 13568342 C820P006-0002 INTRLK Reactin Gas Y2 OPDC 09/13/2022 13568343 C820P007-0002 PLC SFTY INTRLK L2 6 MO OP 09/14/2022 13575719 S810P001 VESSEL FOR STATE/INSP 1MO RE 10/03/2022 13575978 C810P009-0002 DC AUTOCLAVE 6MO MWHZ 10/10/2022 13576031 C841I001 TRANSMITTER HF 6 MONTH CALIB. 10/22/2022 13580274 C840P002-0002 MONITOR URANIUM HF 1WK IN 11/06/2022 13580275 C840P002-0003 MONITOR URANIUM HF 1WK IN 11/06/2022 88050 Corrective Action CR 2020-2260 2020 Q4 Criticality Evacuation Drill Observations 01/21/2021 Documents CR 2022-1239 Lessons Learned from 2022 HRR PERMT/PERT 05/06/2022 Emergency Field Exercise CR 2022-1474 2022 Q2 HRR Criticality Evacuation Exercise 06/03/2022 CR 2022-1759 Food in Microwave oven overheated allowing smoke to 07/14/2022 escape 18
Inspection Type Designation Description or Title Revision, Procedure Version, or Date CR-2020-1306 2020 Q2 Criticality Evacuation Drill Observations 01/21/2021 CR-2020-2224 Internal Audit 20:55 Improvement Points 01/29/2021 CR-2021-0867 2021 Q2 Criticality Evacuation Drill Observations 08/09/2021 CR-2021-2499 2021 Q4 Criticality Evacuation Exercise 03/24/2022 CR-2022-2657 2022 Q4 HRR Criticality Evacuation Exercise 10/21/2022 Corrective Action CR-2022-3009 2022 EP Inspection Observations 11/17/2022 Documents Resulting from Inspection Miscellaneous Richland HRR Site: EHS&L Organization - Nov 2022 11/01/2022 Framatome Richland Workforce Schedule 11/14-2022 through 11/20/2022 E08-04-2.12 Memorandum of Understanding Between Framatome Inc. 10/24/2022 and City of Richland, Fire & Emergency Services November 2022 E08-04-2.2 Memorandum of Understanding Between Framatome Inc. 11/19/2021 and Kadlec Regional Medical Center August 2018 JMD:22:001 2022 PED Duty List 02/09/2022 JMD:22:002 2022 IC Duty List 02/09/2022 Personnel Training Discussion-Based Exercise For Interim Plant Emergency 10/20/2022 Roster Director -Criticality Evacuation Training 2021 Annual EP Orientation for Offsite Agencies and 2021 Nearby Neighbors Training HRR Site EP Orientation for Fire Departments 2022 Procedures E08-03-8.13A Criticality Alarm for IPED on Backshifts, Weekends, Version 3.0 Holidays E12-03-001 Review of EP Plan and Relevant Procedures Version 5.0 E12-03-002 Independent Audit of EP Program Version 8.0 E12-03-002-FRM- Independent Audit of EP Program - Checklist Version 3.0 001 MCP-30379 Construction or Modification Change Control Version 19.0 Self- 21:56 US Fuel Internal Audit Report: EHS&L Emergency 11/16/2021 19
Inspection Type Designation Description or Title Revision, Procedure Version, or Date Assessments Preparedness Program - Richland, WA 22:55 US Fuel Internal Audit Report: EHS&L Emergency 08/01/2022 Preparedness Program - Richland, WA FRA_D3SEP_IG_22- 2022 Triennial Emergency Preparedness Assessment 09/02/2022 031_IR JMD:21:008 Semi-Annual Criticality Evacuation Drill April8, 2020 - 05/14/2021 After Action Report JMD:21:015 2021 Annual Review of Emergency Plan and Relevant 09/20/2021 Procedures JMD:21:016 Semi-Annual Criticality Evacuation Drill -October 14, 2021 11/18/2021
- After Action Report JMD:22:006 After Action Report for Framatome Richland Facility 06/17/2022 emergency Field Exercise conducted on April 27, 2022 JMD:22:007 2022 Annual Review of Emergency Plan and Relevant 06/23/2022 Procedures JMD:22:008 After Action Report for Semi-Annual Criticality Evacuation 07/15/2022 Exercise on June 2, 2022 Work Orders 13547633 CG06P011 Fire Alarm Bldg. Evac 12 Months; IROFS 03/30/2022 Fire/Gas Detection System 13571604 PM005067 SCBA Inspection 1Monthly SA: PM000091 09/28/2022 Emergency Repository & First Aid Equipment 1 Monthly SAFE -
13576362 PM005731 Parking Lot Badge Reader 3 Month SA 10/25/2022 13579340 PM005067 SCBA Inspection 1Monthly SA- ES Safety 11/01/2022 Equip Air PAKS First Aid ETC 13579342 PM000091 Emergency Repository & First Aid Equipment 11/01/2022 1 Monthly SAFE -
88072 Corrective Action 2017-4604 Weight Limit Interlock Failed to Function at MURS; Not an Documents NCS Infraction 2017-6541 NCS Infraction 2017-027, C080P011 AS16P Overflow/Drain PM failed; IROFS 6203 failed.
2018-5593 NCS Infraction 2018-013, MURS Furnace Scale Weight Interlock Failure to Function IROFS 6527 Failed 20
Inspection Type Designation Description or Title Revision, Procedure Version, or Date 2019-1090 NCS Infraction 2019-009, Improper Storage of Moderated (UMW) SNM bucket at MURS; IROFS 2106.10 Degraded 2019-3281 Calibration C1601101 IROFS 1402; Not A NCS Infraction 2019-3977 NCS Infraction 19-024 - Bucket labelled Moderated found stored in dry storage array in UO2 Room 180; IROFS 2106 Degraded 2021-3125 Calibration C1501101, Out of Tolerance; Not an NCS Infraction CR-2017-6541 NCS Infraction 2017-027, C080P011 AS16P 10/26/2017 Overflow/Drain PM failed. IROFS 6203 failed.
CR-2019-1090 NCS Infraction 2019-009, Improper Storage of Moderated 05/14/2019 (UMW) SNM bucket at MURS. IROFS 2106.10 Degraded.
CR-2019-4003 Chemical Exposure to Operator 11/11/2019 CR-2021-0381 MURS Could Electrocute and Kill an Operator 02/17/2021 Corrective Action CR-2022-2709 TBD 10/27/2022 Documents Resulting from Inspection Drawings CSA 611/150 MISC. Uranium Recovery System PI&D Revision 7 CSA 606/826 UF6 Conversion MURS Overflow Tank 702 Revision 1 CSA 611/080 Line 2 Uranium Recovery P&ID Revision 3 CSA 611/150 Miscellaneous Uranium Recovery System P&ID Revision 2 CSA-608/295 Oxidation Furnace Tray Loading Enclosure Assay Revision 7 CSA-610/555 MURS ADU Furnace; MURS Oxidation Tray Revision 7 CSA-611080 ADU IX Column V-167 P&ID Revision D, Sheet 11 CSA-611080 ADU IX Column V-168 P&ID Revision D, Sheet 12 CSA-611080 ADU IX Column V-169 P&ID Revision D, Sheet 13 CSA-611080 ADU Process Uranium Recovery P&ID Revision 18, Sheet 10 Engineering ECN 1424 MURS New System 02/21/1985 21
Inspection Type Designation Description or Title Revision, Procedure Version, or Date Changes ECN 4425 Pumps Upgrade MURS Facility 08/27/1996 ECN 5325 MURS PLC Replacement 03/25/1996 ECN 5358 MURS Oxidation Pan Furnace Modification 01/25/1996 ECN 5368 MURS pH and U Upgrade 08/20/1997 ECN 5391 MURS Facility Strainer Modification 12/12/1995 ECN 5460 MURS Oxidation Furnace Modification 02/21/1996 ECN 5614 MURS 703 Pumpout Line Modification 05/22/1996 ECN 5971 Isolation Valves Ion Exchange Columns MURS Facility 12/02/1996 ECN 6835 MURS Acid Cleaning Modification 04/21/1999 ECN 6888 Scope of Work Request- Remove MURS Tank 704 11/30/1999 ECN 6988 Replace MURS Facility 704 Tanks 04/03/2000 ECN 6989 Modify MURS facility Furnace Tray 12/12/1999 ECN 7505 MURS IX Column Pipe Change 07/02/2002 ECN 7790 MURS Facility 703 Pump Modification 09/15/2003 ECN 7831 Isolate the MURS IX Columns 06/15/2004 ECN 7838 MURS 703 Tank Piping Removal 01/23/2004 ECN 7883 MURS IX System Changes 11/03/2004 ECN 8911 Demo and Prep ECN 8931 ADU IX Installation EMF-1955 Criticality As-Build Checklist Revision 0 Engineering Equipment Acceptance Test Procedure and Review 02/21/1985 Evaluations (Exxon Nuclear Company)
E04-NCSA-080 ADU Uranium Recovery Version 25 E04-NCSA-163 Industrial Waste Water Treatment Facilities Version 34 EMF 614, 648 Tank Support MURS Facility Tank 704 March 2000 Miscellaneous Project Information & Design/Drafting Request 11/16/1995 List of Support/Process Engineering Assignments ECN 5325C Work scope MURS PLC Replacement 08/20/1996 FRM-30379Q Functional test of the IX Installation & Modifications for Version 2.0 ENC 8931 Organizational Chart Fuel Operations - Plant Engineering, Technical Support &
Maintenance 22
Inspection Type Designation Description or Title Revision, Procedure Version, or Date Procedures AID-30379 C Project Risk Assessments Version 2.2 AID-30379 D Test Procedure and Document Review Version 4.0 AID-30379 E Design Reviews Version 2.0 MCP-30147 Startup Council Version 9.0 MCP-30153 Guidelines for Design and Documentation Requirements Version 7.0 for Critical Components MCP-30379 Construction or Modification Change Control Revision 19.0 MCP-30379 A Construction or Modification Change Control - Initiation Version 6.0 MCP-30379 B Construction or Modification Change Control - Planning Version 3.4 MCP-30379 C Construction or Modification Change - Execution Version 12.0 MCP-30379 D Construction or Modification Change Control - Controlling Version 7.0 MCP-30379 E Construction or Modification Change Control - Closure Version 4.1 MCP-31044 MURS (System 150) Revision 3.0 SOP-40244 Miscellaneous Uranium Recovery Revision 16.0 SOP-40245 MURS Furnace Operation Revision 7.0 SOP-40273 Ion Exchange Operation and Regeneration - ADU Line 2 Version 8.0 SWI-40245A MURS Furnace Operation Revision 7.0 Self- MMD-21-003 Annual Configuration Control Audit Report - 2021 12/29/2021 Assessments Work Orders 11552182 UCAR-Cylinder Wash Dry Station Glass Cracked 10/26/2022 11552183 UNH Decon Hood Glass 10/26/2022 13539352 C080P024 - IX Pre Filter 3MO OPCH 01/27/2022 13551776 C080P024 - IX Pre Filter 3MO OPCH 04/22/2022 13564875 C080P024 - IX Pre Filter 3MO OPCH 07/25/2022 1357650 C080P024 - IX Pre Filter 3MO OPCH 10/05/2022 C05325C Equipment Acceptance Test Procedure, ATP 96-007; 08/20/1996 MURS PLC Replacement E05460S MURS Oxidation Furnace 02/22/1996 E06988C Unfavorable Geometry Tanks and Equip Review 10/06/1999 23
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