ML23115A238

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Westinghouse Columbia Fuel Fabrication Facility - Integrated Inspection Report 07001151/2023001
ML23115A238
Person / Time
Site: Westinghouse
Issue date: 04/26/2023
From: Eric Michel
NRC/RGN-II/DFFI/FFB2
To: Pope A
Westinghouse
References
IR 2023001
Download: ML23115A238 (17)


Text

April 26, 2023 Annette Pope Plant Manager Westinghouse Electric Company 5801 Bluff Road Hopkins, SC 29061

SUBJECT:

WESTINGHOUSE COLUMBIA FUEL FABRICATION FACILITY - INTEGRATED INSPECTION REPORT 07001151/2023001

Dear Annette Pope:

This letter refers to the Nuclear Regulatory Commission inspection activities conducted between January 1 and March 31, 2023, for the Westinghouse Columbia Fuel Fabrication Facility. On February 9 and March 16, 2023, the NRC inspectors discussed the results of this inspection with you. The results of this inspection are documented in the enclosed report.

No violations of more than minor significance were identified during this inspection.

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

Sincerely, Signed by Michel, Eric on 04/26/23 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

ML23115A238 X Non Sensitive X Publicly Available X SUNSI Review Sensitive Non-Publicly Available OFFICE RII/DFFI RII/DFFI NAME T. Vukovinsky E. Michel DATE 4/25/2023 4/26/2023 U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number: 07001151 License Number: SNM-1107 Report Number: 07001151/2023001 Enterprise Identifier: I-2023-001-0054 Licensee: Westinghouse Electric Company Facility: Westinghouse Columbia Fuel Fabrication Facility Location: Hopkins, SC Inspection Dates: February 06, 2023, to March 17, 2023 Inspectors: J. Grice, Fuel Facility Inspector N. Peterka, Fuel Facility Inspector L. Pitts, Sr. Fuel Facility Projects Inspector J. Rivera Ortiz, 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 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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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 2600, Fuel Cycle Facility Operational Safety and Safeguards Inspection Program. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

SAFETY OPERATIONS 88015 - Nuclear Criticality Safety The inspectors evaluated selected aspects of the licensees nuclear criticality safety (NCS) program to verify compliance with selected portions of Title 10 of the Code of Federal Regulations (10 CFR) 70, Domestic Licensing of Special Nuclear Material, including 70.24, 70.61, 70.62; chapter 6, Nuclear Criticality Safety 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 sections of the license application. Specifically, the inspectors interviewed licensee staff and reviewed the following CSEs:

CSE-4-I, "Criticality Safety Evaluation for Processing Ash from 55-gallon Drums," Revision (Rev.) 1, including review of what-if analysis, normal, credible abnormal, and non-credible accident sequences CSE-1-E, "Criticality Safety Evaluation for the S-1030 Scrubber System,"

Rev. 21, including the review of selected accident sequences involving accumulation of material in the scrubber and ducts; the inspectors conducted walkdowns to verify that the inputs to the scrubber, and selected controls on those inputs, where consistent with the CSE CSE-17-E, Criticality Safety Evaluation for The Columbia Fuel Fabrication Facility Fuel Assembly Storage Area and Boiling Water Reactor Fuel Bundle Inspection Area," Rev. 2, including the review of what-if analysis, normal, credible abnormal, and non-credible accident sequences, and the IROFS that were established to prevent criticality for accident scenarios 4.1.1 and 4.1.2 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 staff interviews to verify compliance with 10 CFR 70 and applicable sections of the license application. Specifically, the inspectors interviewed licensee staff and reviewed the following controls and their management measures associated with the CSEs listed above and other selected areas:

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FA-105, a passive engineered control to store and maintain the spacing of fuel assemblies, and walked down the storage racks and reviewed the as-built and field verification records ASH-100, an administrative control to prevent the accumulation of material in the receiving dock, and associated procedure ASH-101, an administrative control to detect overweight bags of material and moderator, and associated procedure VENT-S1030-124, an administrative control to prevent excessive liquid from accumulating in the scrubber bottom, and associated procedure VENT-S1030-127, an administrative control to inspect and mitigate the buildup of uranium in the scrubber, and associated procedure and inspection records VENT-S1030-130, an administrative control to limit the amount of uranium particulate from entering the ventilation and scrubber systems, and associated inspection records Criticality Operational Oversight (IP Section 02.03)

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

interviewed NCS and process engineering staff concerning criticality hazards and control methods including monitoring for and cleaning out long-term accumulations in the S-1030 scrubber and ducts; reviewed NCS oversight of accumulation cleanouts reviewed the documentation of selected NCS weekly facility walkthrough assessments performed by the licensee over the last year interviewed conversion room operators on response to alarms for the S-1030 scrubber and the associated operating procedure Criticality Programmatic Oversight (IP Section 02.04)

The inspectors reviewed NCS program procedures, audits, and NCS staff qualifications to verify compliance with 10 CFR 70 and applicable sections of the license application.

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

discussed qualification and training status of the NCS staff with NCS management interviewed NCS staff concerning the NCS review of changes including changes to operating procedures that may affect NCS and changes to the facility the most recent revision to licensee procedure RA-302, Criticality Postings 4

Criticality Incident Response and Corrective Action (IP Section 02.05)

The inspectors reviewed the licensees criticality accident alarm system (CAAS) and corrective action program (CAP) to verify compliance with 10 CFR 70 and applicable sections of the license application including section 6.1.8. Specifically, the inspectors observed activities, reviewed documents, and interviewed licensee staff concerning the following:

reviewed selected issues entered in the CAP pertaining to items relied on for safety (IROFS) and audit findings reviewed selected 2022 surveillance and maintenance records for the CAAS the annual NCS evacuation drill records for 2022 88055 - Fire Protection The inspectors evaluated selected aspects of the licensees fire protection program to determine whether the operational status, material condition, and design of fire protection systems met the applicable requirements of 10 CFR 70, chapter 8, Fire Protection Program, of the facilitys license application, and applicable licensee procedures.

Selection of Inspection Samples (IP Section 02.01)

The inspectors reviewed licensing documents to select a sample of fire protection features in risk-significant areas/processes including IROFS and their respective management measures (where applicable). The inspectors also selected licensee activities that support the implementation of the fire protection program based on the program description included in the license application. Specifically, the inspectors selected the following fire protection features and licensee activities for review as discussed in more detail sections 02.02 through 02.07:

combustible controls and fire protection features in fire area CHEM-02 housing the ammonium diuranate (ADU) conversion system combustible controls and fire protection features in hot oil room combustible controls in mechanical areas where combustible metals are used controls of ignition sources and inert atmospheres in fire area CHEM-02 pre-fire plans and fire hazard analyses for fire area CHEM-02 management measures for selected administrative, passive, and active engineered IROFS training and qualification of emergency response personnel compensatory measures for fire-related impairments general operation of the fire water suppression system audits and self-assessments of the fire protection program Preventative Controls (IP Section 02.02)

The inspectors interviewed licensee staff, reviewed documentation, and conducted plant walkdowns to verify the licensees controls for combustibles, ignition sources, and inert atmospheres met the license requirements and applicable requirements in 10 CFR 70.

Specifically, the inspectors conducted the inspection activities listed below:

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interviewed licensee staff and management, reviewed program documents and maintenance records, and walked down various areas of the plant to verify compliance with paragraph 8.1.1.6 of the license application for storage of flammable liquids interviewed licensee staff and management, reviewed program documents and maintenance records, and walked down various areas of the plant to verify the licensee's combustible control program was being implemented as required by and to verify compliance with paragraph 8.1.1.13 of the license application for housekeeping practices interviewed licensee staff and management, performed system walkdowns, reviewed procedures, and completed maintenance records to verify the following IROFS were being maintained as required to ensure they remained available and reliable to perform their safety function:

o ADUSC-904, nitrogen purge o CHEM-407-NG, excess flow shutoff valves (natural gas) o FIRE-901, combustible controls o SOLX-906, valve alignment to prevent solvent spill reviewed procedures to verify compliance with paragraph 8.1.1.5 of the license application regarding cutting, welding, and hot work permit procedures reviewed procedures to verify compliance with paragraph 8.1.4.5 of the license application regarding machining operations on combustible metals reviewed samples of hot work permits issued in calendar years 2021 and 2022 conducted a walkdown of the grid mechanical area to observe combustible controls for combustible metals reviewed procedures for inert atmosphere controls applicable to the sintering furnaces in the pelleting process area conducted a walkdown of pelleting furnace 4A with a process engineer to observe ongoing operations and discuss the process safety controls listed below to verify compliance with paragraph 8.1.4.2(c) of the license application regarding process fire safety for flammable gases:

o PELSINT-901, Flame Sensor on Exhaust Flare Pilot Interlock o PELSINT-904, Zone 2 Low-Temperature Interlock o PELSINT-909, Furnace Superpurge o PELSINT-919, Furnace Natural Gas Pressure Loss o PELSINT-920, Furnace Draft Flow Interlock o PELSINT-922, Furnace Hydrogen Supply Low Flow Interlock o PELSINT-924, Furnace Pressurization Gas Interlock o PELSINT-925, Furnace Purge Confirmation o PELSINT-927, Super Purge Flow Regulation o PELSINT-928, Furnace Doors Provide Blast Relief reviewed records of recent functional verification of safety controls for pelleting furnaces in pelleting line 4 Fire and Gas Detection and Alarm Systems (IP Section 02.03)

The inspectors reviewed selected fire or gas detection devices to verify that detection and alarm systems were able to detect the minimal fire within the required time and initiate the 6

safety function credited in the license application and fire hazard analysis. Specifically, the inspectors conducted the inspection activities listed below:

conducted walkdowns of the ADU conversion area to verify compliance with paragraph 8.1.1.3 of the license application regarding fire alarm pull stations and fire detection conducted walkdowns of the hot oil room, ADU conversion, and chemical area 02 to verify compliance with section 8.1.5 of the license application regarding fire detection and alarm systems reviewed records of fire detection and alarm system testing in the ADU conversion system observed pre-job briefing and testing of heat detectors in hot oil room (HD-7 detectors) on March 15, 2023 reviewed fire protection drawings to verify the location of heat detectors in the hot oil room was consistent with the actual plant configuration Suppression Systems and Activities (IP Section 02.04)

The inspectors interviewed license staff, reviewed fire protection program documents, and conducted plant walkdowns to verify that suppression systems were capable of performing the safety function credited in the license application and fire hazard analysis. Specifically, the inspectors performed the following activities:

interviewed licensee emergency response staff and management and walked down the restoration of emergency response equipment after performance of a fire drill to verify the licensee carried out its responsibility to maintain emergency response equipment, firefighting equipment, and fire suppression systems interviewed licensee emergency response staff and management, walked down the fire water system, and observed use of fire water during fire brigade response to a simulated fire to verify that fire suppression activities would not damage would not damage safety controls interviewed licensee emergency response staff and management, walked down the fire water system, and observed use of fire water during fire brigade response to a simulated fire to verify adequate drainage and environmental protection was provided in areas protected by water suppression systems to preclude or limit release of effluents reviewed inspection and test records and walked down fire suppression equipment (fire water tanks and pumps, hydrants, standpipes, automatic sprinkler systems, and portable fire extinguishers) to verify compliance with paragraphs 8.1.6.1 and 8.1.6.2 of the license application interviewed licensee staff and management, performed system walkdowns, reviewed procedures, and completed maintenance records to verify IROFS FIRE-902, "Fire Fighting Methods," was being maintained as required to ensure they remained available and reliable to perform its safety function Passive Fire Protection Features (IP Section 02.05)

The inspectors reviewed selected passive fire protection features to verify these were in a proper material condition to perform the safety function credited in the license application, 7

fire hazard analysis (FHA), and the ISA summary. Specifically, the inspectors performed the following activities:

interviewed licensee staff, reviewed program documents and management measures, and conducted walkdowns to verify the passive IROFS listed below associated with the ADU conversion system were maintained, as necessary, to ensure they were available and reliable to perform their function o ADUHOS-405 - fire door to hot oil room o ADUHOS-906 - hot oil room fire barriers (fire walls, wall penetration seals, doors, and ceiling) o ADUHOS-910 - hot oil room dike o ADUSCR-901 - calciner seals Fire Protection Program Elements (IP Section 02.06)

The inspectors reviewed selected fire protection program elements to verify compliance with the license requirements. Specifically, the inspectors completed the following activities:

reviewed examples of compensatory measures put in place for out-of-service, impaired, degraded, or inoperable fire protection equipment, systems, or features interviewed two fire brigade members and two incident commanders, walked down fire brigade equipment, and reviewed drill records to verify implementation of management measures for IROFS-902 reviewed emergency response personnel training and general fire protection training to verify compliance with paragraphs 8.1.1.11 and 8.1.7 of the license application interviewed the emergency preparedness manager and reviewed training records and evacuation drill completion records to verify compliance with paragraph 8.1.1.7 of the license application observed performance of fire brigade response for an emergency drill conducted on March 14, 2023, that included the simulation of a fire, hazardous material spill and multiple injured personnel interviewed licensee staff in charge of the fire protection function regarding changes in the organization and deviations from National Fire Protection Association (NFPA) code provisions, if any, to verify compliance with paragraph 8.1.1.1 of the license application regarding the authority having jurisdiction at the site observed emergency communications during the emergency response exercise of March 14, 2023, to verify compliance with paragraphs 8.1.1.4 and 8.1.1.14 of the license application interviewed licensee staff, reviewed emergency lighting preventive maintenance activities (PM20512, PM20513, and PM20511), and walked down the mechanical side emergency lights to verify compliance with paragraph 1.1.2.1 of the license application and section 7.9 of NFPA 101, "Life Safety Code" reviewed the process safety analysis for the ADU conversion system area to verify compliance with sections 8.1.4 and 8.1.9 of the license application reviewed the pre-fire plan for the ADU conversion system area to verify compliance with section 8.1.8 of the license application 8

conducted a walkdown of the ADU conversion area to verify consistency between the FHA and the current plant configuration Identification and Resolution of Problems (IP Section 02.07)

The inspectors reviewed the licensees identification and resolution of fire protection issues to verify compliance with the license requirements. Specifically, the inspectors reviewed the following CAP entries, audits, and self-assessments:

reviewed the licensee's fire protection audit, EHS-20-8, "Regulatory Component Audit for the Fire Protection Program," dated February 11, 2022, to verify compliance with sections 3.6 and 8.1.10 of the license application reviewed a sample of CAP entries related to fire issues to verify compliance with sections 3.7 and 3.8 of the license application (see "Documents Reviewed" section of this report)

INSPECTION RESULTS No issues were identified.

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

On February 9, 2023, the inspectors presented the NCS inspection results to Annette Pope and other members of the licensee staff.

On March 16, 2023, the inspectors presented the fire protection results to Annette Pope and other members of the licensee staff.

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DOCUMENTS REVIEWED Inspection Type Designation Description or Title Revision or Procedure Date 88015 Corrective Action IR-2023-506 NCS-related CAP entries Documents IR-2022-6973 IR-2022-7014 IR-2022-8297 IR-2022-10374 IR-2022-6501 Drawings 436F03EQ02 144-Inch Rack Assembly Fuel Storage Racks Rev. 1 703F16EQ06 Scrubber S-1030 Assembly Rev. 2 Engineering CSE-1-E Criticality Safety Evaluation for the S-1030 Scrubber System Rev. 21 Evaluations CSE-17-E Criticality Safety Evaluation for The Columbia Fuel Rev. 2 Fabrication Facility Fuel Assembly Storage Area and Boiling Water Reactor Fuel Bundle Inspection Area CSE-17-G Criticality Safety Evaluation for The Columbia Fuel Rev. 2 Fabrication Facility Packing Area CSE-4-I Criticality Safety Evaluation for Processing Ash from 55- Rev. 1 Gallon Drums PSEDoc-0008313 S-1030 Elbow Sprays Rev. 0 PSEDoc-0009284 Evaluation of Proposed Changes to CSE-1-E Revision 21 Rev. 0 Miscellaneous Hematite Suspect Ash Excel Sheet AAR-10012 QAP Boral Data Package Record Checklist 04/29/2005 CF-81-247 Scrap Cage Blu-M Oven Filter Log Various CF-81-248 S-1030 Inspection Data Sheet 04/26/2022 CF-81-250 S1030 Conversion Scrubber Mass Quantification 04/27/2022 RAF-314-I CSE Implementation Checklist for CSE-21-A 05/22/2006 SEPF-013-1 Post Incident Analysis for 2022 Criticality Safety Evacuation Various Drills Procedures CN-SB-18-001 Baseline Integrated Safety Analysis (ISA) and ISA Summary Rev. 1 Handbook COP-815010 Conversion BLU-M Oxidation Rev. 34 COP-815020 Scrap Recovery Scrubber S-1030 Rev. 32 COP-815021 S-1030 Inspection and Cleanout Rev. 25 COP-836082 Processing of Hematite Ash Rev. 4 10

Inspection Type Designation Description or Title Revision or Procedure Date MCP-202037 Criticality Alarm Calibration and SSC Verification (AC-Plant- Rev. 32 1-01)

MCP-203445 GA-7M Criticality Accident Alarm System and SSC Rev. 3 Verification (AC-Plant-1-01)

MCP-203528 CAAS GA-7M-GD-6 Setup and Lab Calibration Rev. 2 RA-302 Criticality Postings Rev. 18 Self-Assessments RAF-316-1 Nuclear Criticality Safety Checklist for NCS Facility 09/21/2022 Walkthrough Assessments, Conversion - Roof Maintenance Operator RAF-316-1 Nuclear Criticality Safety Checklist for NCS Facility 12/21/2022 Walkthrough Assessments, Conversion - IFBA FA3 RAF-316-1 Nuclear Criticality Safety Checklist for NCS Facility 12/21/2022 Walkthrough Assessments, Final Assembly (Ops, UCON, Rod Storage and Handling)

RAF-316-1 Nuclear Criticality Safety Checklist for NCS Facility 12/21/2022 Walkthrough Assessments, Final Assembly (Wash Pit, Assembly Storage and BWR Fuel Bundle Inspection Area, Packing)

Work Orders 107786 26 Weeks OM81037 SI-Safety, S1030 Packing Baskets, 04/29/2022 Body, Inlet Trans., and Baffle Insp. and Cleaning 127101 26 Weeks PM20852a SI-Safety, Instrument Calibration, 08/11/2022 Alarm Sta-18A 127427 26 Weeks PM20852a SI-Safety, Instrument Calibration, 08/23/2022 Alarm Sta-1A 154194 52 Weeks PM20563 SI-Safety, Crit Horn Sound Check 01/19/2023 155500 13 Weeks OM81804 SI-Safety, Blue-M Filter Housing 01/05/2023 Inspection 88055 Calculations CALC-194-8169- Columbia Fuel Fabrication Facility Combustible Loading Rev. 0 01 Corrective Action IR-2021-4365 CAP entries reviewed under IP 88055, section 02.07 Various Documents IR-2021-4860 IR-2021-5777 IR-2021-6909 IR-2021-9948 11

Inspection Type Designation Description or Title Revision or Procedure Date IR-2021-10004 IR-2021-10048 IR-2021-13508 IR-2022-5039 Corrective Action IR-2023-2734 NRC inspectors discovered a potential issue with emergency 03/16/2023 Documents light emergi-lite G12SV24M-2LJ-NEXRF Resulting from IR-2023-2920 NRC fire protection inspection exit meeting 03/16/2023 03/22/2023 Inspection IR-2023-2921 NRC observations following the fire protection inspection exit 03/22/2023 meeting on 03/16/2023 Drawings 510F01EL03 Fire Protection Chemical Area & Outside Rev. 49 324F11PI01 ADU Pellet Line 4 / Facilities, Sheet 4 Rev. C2 324F11PI03 Furnace 4C Natural Gas Supply, Sheet 7 Rev. 01 &

C1 324F11PI03 Sintering Furnace 4C Mechanical/Heating, Sheet 5 Rev. 01 324F11PI03 Sintering Furnace 4C Piping & Instrumentation Drawing, Rev. 01 Sheet 4 510F05EL03 Plant Utilities / Lighting - Battery Powered Emergency Rev. 9 Lighting Mechanical Side & Office Areas - First Floor 510F05EL03 Plant Utilities / Lighting - Battery Powered Emergency Rev. 18 Lighting Light Schedule Engineering FHA-13-001 Fire Hazard Analysis Columbia Fuel Fabrication Facility Rev. 3 Evaluations FHA-13-001 Fire Hazard Analysis Columbia Fuel Fabrication Facility, Rev. 0 Appendix CHEM-02, ADU Process Area Fire Plans Fire Pre-Plan 3 ADU Conversion & Scrap Recovery Area (CHEM-02) 10/10/2022 Fire Pre-Plan 70 UF6 Bay (CHEM-04) and Hot Oil Room Area (CHEM-05) 10/14/2022 Miscellaneous CF-82-097 Pellet Area: Safety Significant Control Verification Form for Completed Pellet Line 4, Furnace 4A 03/21/22 CF-82-097 Pellet Area: Safety Significant Control Verification Form for Completed Pellet Line 4, Furnace 4B 01/28/22 CF-82-097 Pellet Area: Safety Significant Control Verification Form for Completed Pellet Line 4, Furnace 4C 04/28/22 HWP-2022-0983 Hot Work Permit - Spiking Station 03/21/2022 HWP-2022-0993 Hot Work Permit - Spiking Station 03/31/2022 HWP-2022-1168 Hot Work Permit - Incinerator Room 11/10/2022 12

Inspection Type Designation Description or Title Revision or Procedure Date S4098-0014-10 Simplex Vendor Manual 04/2015 SYF-306-5 Fire Protection Impairment Form, Node 5 09/28/2021 SYF-306-5 Fire Protection Impairment Form, PM81905 04/22/2022 Procedures CF-81-932 Conversion Line 1: Safety Significant Interlocks, Alarms, & Rev. 74 Passive Engineered Controls Functionality Verification Form CF-81-933 Conversion Line 2: Safety Significant Interlocks, Alarms, & Rev. 70 Passive Engineered Controls Functionality Verification Form CF-81-934 Conversion Line 3: Safety Significant Interlocks, Alarms, & Rev. 64 Passive Engineered Controls Functionality Verification Form CF-81-940 Conversion Line 4: Safety Significant Interlocks, Alarms, & Rev. 70 Passive Engineered Controls Functionality Verification Form CF-81-941 Conversion Line 5: Safety Significant Interlocks, Alarms, & Rev. 62 Passive Engineered Controls Functionality Verification Form CF-83-700 LOTO URRS Incinerator Scrubber System Rev. 3 COP-815417 Functional Verification of Safety Significant Controls Rev. 24 Conversion Area COP-820301 Sintering Furnace Operation Rev. 84 COP-820303 Sintering Furnace Operating with Enhanced Safety Systems Rev. 36 COP-829040 Functional Verification of Safety Significant Controls Pellet Rev. 9 Sintering Furnaces with Enhanced Safety Systems COP-830110 SOLX & Product Concentrator System 1 - Startup & Rev. 45 Operation COP-830111 SOLX & Product Concentrator System 2 - Startup & Rev. 34 Operation COP-830128 Adjusting and Making-up Solvent for Solvent Extraction Rev. 15 Systems 1 & 2 COP-830210 Incinerator Operation Rev. 57 MCP-108232 Maintaining Integrity of Fire Barriers Rev. 3 SEPF-009-6 Command Check Sheet - Fire Response Westinghouse Rev. 11 Nuclear Fuel Columbia, SC SYP-122 Hydrogen & Natural Gas Safety Rev. 1 SYP-207 Cutting, Welding, and Hot Work Rev. 42 SYP-300 Combustible and Ignition Control Rev. 31 SYP-301 Handling and Storage of Zirconium and its Alloys Rev. 18 13

Inspection Type Designation Description or Title Revision or Procedure Date SYP-303 Portable Fire Extinguisher Inspection and Maintenance Rev. 12 SYP-305 Fire Watch Safety Rev. 10 SYP-306 CFFF Fire/Criticality System Impairment Rev. 23 SYP-311 Pre-Fire Plans Rev. 1 SYP-313 Site Fire Prevention Plan Rev. 0 Self-Assessments EHS-AUDIT-20-8 Regulatory Component Audit for the Fire Protection Program 02/11/2021 Work Orders OM11060 Lab Area Housekeeping Inspection Completed 03/03/2023 OM75012 Flammable Cabinet Inspection - ADU Rods Completed 02/17/2023 OM75017 Housekeeping Inspection - ADU Rods Completed 02/17/2023 OM81086 52 wk SI-Safety, Hot Oil Room Dike Inspection (IROFS Completed ADUHOS-910) 04/30/2022 OM81117 Housekeeping and Flammable Storage Cabinet Inspection - Completed Conversion 03/06/2023 OM86016 Area Housekeeping and Flammable Storage Cabinet Completed Inspection-ERBI 02/06/2023 PM20149 52 wk Door Closer-Holder w/smore detector inspection, Completed FCLT 02/03/2023 PM20195 52 wk Fire Alarm System, Chemical Area Completed 03/04/2022 PM20196 52 wk Fire Alarm System, ERBIA Area Completed 08/31/2022 PM20208 Chem-407, Natural Gas Bypass Inspection Completed 12/15/2022 PM20313 52 wk Fire Alarm System, Chemical Area Linear Heat Completed Detection 09/30/2022 PM20511 Emergency Units and Lights Chemical Side Completed 02/28/2023 PM20512 Emergency Units and Lights Mechanical Side Completed 03/06/2023 PM20513 Emergency Units and Lights Outside Areas Completed 02/21/2023 14

Inspection Type Designation Description or Title Revision or Procedure Date PM20915 52 wk Fire Doors without holders, FCLT-Structures and Completed Spaces, Chem and Mech 09/21/2022 PM20917 26 wk Fire Alarm System Open-Area-Smoke Imaging Completed Detection, FCLT 11/03/2022 PM20918 52 wk Fire Alarm System, Open Area Some Imaging Completed Detection, Chemical Area 11/07/2022 PM81018 52 wk Hot Oil System External Mechanical Integrity Completed Inspection, 05/25/2022 PM81085 52 wk Hot Oil Room Integrity Inspection (IROFS ADUHOS- Completed 405 and -906) 07/19/2022 PM81803 26 wk SI-Safety-Front End Seal Maintenance (IROFS Completed ADUSCR-901) 02/24/2023 PM81804 26 wk SI-Safety-Discharge End Seal Maintenance (IROFS Completed ADUSCR-901) 03/06/2023 15