ML23200A012

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BWXT Nuclear Operations Group, Inc. - Integrated Inspection Report 07000027/2023002
ML23200A012
Person / Time
Site: 07000072
Issue date: 07/18/2023
From: Eric Michel
NRC/RGN-II
To: Bittner J
BWXT
References
IR 2023002
Download: ML23200A012 (1)


Text

July 18, 2023 James J. Bittner Vice President and General Manager BWXT Nuclear Operations Group, Inc.

P.O. Box 785 Lynchburg, VA 24505-0785

SUBJECT:

BWXT NUCLEAR OPERATIONS GROUP, INC. - INTEGRATED INSPECTION REPORT 07000027/2023002

Dear James J. Bittner:

This letter refers to the U.S. Nuclear Regulatory Commission (NRC) inspection activities conducted from April 1, 2023, to June 30, 2023, for the BWXT Nuclear Operations Group, Inc.,

facility. On June 30, 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 07/18/23 Eric C. Michel, Chief Projects Branch 2 Division of Fuel Facility Inspection Docket No. 07000027 License No. SNM-42

Enclosure:

As stated cc w/ encl: Distribution via LISTSERV

ML23200A012 x Non-Sensitive x Publicly Available x SUNSI Review Sensitive Non-Publicly Available OFFICE RII/DFFI RII/DFFI RII/DFFI NAME N. Peterka M. Doyle E. Michel DATE 07/14/2023 07/18/2023 07/18/2023 U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number: 07000027 License Number: SNM-42 Report Number: 07000027/2023002 Enterprise Identifier: I-2023-002-0064 Licensee: Nuclear Operations Group, Inc.

Facility: BWXT Nuclear Operations Group, Inc.

Location: Lynchburg, VA 24505 Inspection Dates: April 01, 2023, to June 30, 2023 Inspectors: L. Cooke, Fuel Facility Inspector M. Doyle, Senior Resident Inspector K. Sullivan, General Engineer NRAN 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 an integrated inspection at BWXT Nuclear Operations Group, Inc.,

in accordance with the fuel cycle facility inspection program. This is the NRCs program for overseeing the safe operation of licensed fuel cycle facilities. Refer to https://www.nrc.gov/materials/fuel-cycle-fac.html for more information.

List of Violations No violations of more than minor significance were identified.

Additional Tracking Items None.

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PLANT STATUS During the inspection period, routine fuel manufacturing operations and maintenance activities were conducted in the fuel processing areas, the uranium recovery (UR) facility, and the research and test reactors (RTR) facility.

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 88020 - Operational Safety The inspectors evaluated selected aspects of the licensees operational safety 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, 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 sequence information provided in the integrated safety analysis (ISA) summary, safety basis documentation. The inspectors conducted a general plant tour of each major plant operating area. The process areas and accident sequences selected for review are listed below:

safety analysis report (SAR) 15.09, "Main Extraction and Drum Dryer Processes in Uranium Recovery," Revision (Rev.) 107 observed other ongoing processing, sampling, and maintenance activities in UR.

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) for the accident sequences 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.

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This review was performed to verify that the 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:

temperature, pressure, and mass control IROFS EVP 1-3a through EVP 1-3c for prevention of red oil formation in the evaporators listed in SAR 15.09 table 15.9.4.2.1, "Chemical Safety Parameters and Limits, Controls and Control Maintenance."

mass control IROFS EVP 1-1 and EVP 1-2 for evaporators (1 through 6) listed in SAR 15.09 table 15.9.4.1.1, "Criticality Safety Parameters and Limits, Controls, and Control Maintenance."

geometry IROFS SBFE 1-1 for sample boxes and filter enclosures listed in SAR 15.09 table 15.9.4.1.1 mass control IROFS SCHX1-1 and SCHX-2 for steam condensate cooling heat exchangers listed in SAR 15.09 table 15.9.4.1.1 geometry IROFS, CCE1-1, CCE1-2, CCE1-3, CCE1-4, and CCE1-5 for centrifuge contactors and enclosures listed in SAR 15.09 table 15.9.4.1.1 moderation IROFS CCE1-2, CCE1-3, CCE1-4, and CCE1-5 for centrifuge contactors and enclosures listed in SAR 15.09 table 15.9.4.1.1 geometry IROFS DDG-10, DDG-14, and DDG-15 for drum dryer systems enclosure, loading and elevator glove box listed in SAR 15.09 table 15.9.4.1.1 spacing IROFS DDS-1, DDS-2, and DDSS-2 for the drum dryer system listed in SAR 15.09 table 15.9.4.1.1 volume IROFS DDV-1 for drum dryer system listed in SAR 15.09 table 15.9.4.1.1 product piece count IROFS DDMS-1 for drum dryer system listed in SAR 15.09 table 15.9.4.1.1 conducted walkdowns of UR and drum dryer system to verify compliance with mass, geometry, housekeeping, and posting requirements of quality work instruction (QWI) 9.1.7, "Preventive/Predictive Maintenance and Other Safety-Related Controls Testing Program, " Rev. 13 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:

conducted a walkdown of various passive engineered IROFS features identified in nuclear criticality safety (NCS)-2004-069, "Nuclear Safety Release Supporting Phase 5 of SER 03-033, "Centrifugal Contactor System -

Install Contactors and Other Equipment Necessary for the Contactor Operation," including drain system to ensure favorable geometry, equipment installation requirements that limit specific quantity and spacing for the centrifugal contactors in UR and drum dryer system.

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observed various NCS postings in the main extraction and drum dryer areas (i.e., IROFS CCE1-1, DDS-1, DDS-2, DDSS-2, DDPPC-1, and DDMS-1) to control mass, spacing, and moderator limits.

conducted a walkdown of drum dryer system to verify independent and second independent drain in the drum dryer enclosure as described in NCS-2019-014, "Safety Release for a New Recovery Drum Dryer System per SER 17-048 Phase 1."

reviewed CHG-00009650, "Changes to SAR 15.09 and SAR Appendix 15.09 per CA202001323 and Action Item 07588," related to removing uranium concentration control IROFS for the evaporators.

conducted a walkdown of the steam condensate lines in UR for the steam condensate cooling heat exchangers to verify condensate lines terminate above annular tank and siphon breaks were present as described in NCS-2011-075, "Nuclear Safety Release Supporting SER 10-032 (Primary Condensate Annular Tank Install dated 4/28/2011)"

observed UR and drum dryer operations and interviewed one supervisor and three operators.

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. Specifically, the inspectors conducted the following:

observed quarterly uranium sampling and security protocol of sample valve

  1. 120003 for cooling discharge in UR per maintenance plan (MP) 1086, Quarterly Sampling of Cooling Water Discharge for U-235", work order (WO) 20333839 and WO 20338482 reviewed NCS-2006-090, SAP maintenance plan, preventive/predictive maintenance and safety-related controls testing program, QWI 9.1.7 to review the MP, and testing schedule for UR and the drum dryer system.

reviewed MP 3161, "Semi-Annual Pressure Testing for Heat Exchanger Integrity," dated 01/3/2023, WO 20335407 and WO 20324845 reviewed MP 3366, "Evaporators 1-6 Heat Exchanger Integrity Test" dated 08/02/2022 and 02/27/2023, WO 20328390 and WO 20338553 reviewed MP 5146, "Quarterly Sampling of Cooling Water Discharge for U235, Valve 120002," WO 20334943 and WO 20339357 reviewed operating procedure E61-019, "Daily Uranium and Safety Inventory Procedure and Checklist Form," Rev. 14: May 2023 for IROFS SCHX1-2 reviewed OP-0061234, "Operating Procedure for Performing Maintenance in UPRR," Rev. 60 reviewed OP-0061121, "Primary Evaporator Systems," Rev. 33 reviewed corrective action program entries/documents for area process affecting UR IROFS (see document list) reviewed a sample of training qualification records for operators (ID: H3850, H3286, H2206, and H3855) in the UR and drum dryer area; document topics included introduction to recovery, advanced recovery operator functions, recovery scrubber, and drum dryer area activities.

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reviewed audits and assessments of the UR process and drum dryer system (see document list) reviewed HS 2022-020, "Removal of Crediting Trained Operator Utilizing Densitometers as an IROFS in SAR 15.09."

88135.02 - Plant Status The inspectors routinely conducted walkdowns of licensee areas, observed operators, material control and accounting and security force personnel, inspected postings and licensee guidance documents, interviewed plant personnel, and discussed the results of operational and shift turnover meetings to gain insight into the status of facility activities, risk-inform the selection and implementation of the appropriate core inspection procedures, and ensure compliance with license and regulatory requirements.

Plant Tours (IP Section 03.01)

The inspectors performed weekly tours of plant operating areas housing special nuclear material (SNM) to verify that licensed activities were conducted safely and in compliance with the license and 10 CFR 70, Domestic Licensing of Special Nuclear Material.

Status Meetings (IP Section 03.02)

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

attended the annual contractor's seminar on June 16, 2023 Identification and Resolution of Problems (IP Section 03.05)

The inspectors reviewed the selected issues below to determine if the licensee was entering equipment, human performance, and other performance issues in a formalized program to identify, track, and assure correction of safety and safeguard significant problems in accordance with 10 CFR 70.62(a)(3) and applicable license requirements.

CA202300401, incident date April 5, 2023 CA202300453, incident date April 16, 2023 CA202300610, incident date May 2, 2023 CA202300638, incident date May 23, 2023 CA202300643, incident date May 23, 2023 CA202300683, incident date June 1, 2023 CA202300703, incident date June 2, 2023 CA202300711, incident date June 7, 2023 CA202300761, incident date June 18, 2023 CA202300769, incident date June 20, 2023 CA202300771, incident date June 22, 2023 6

Event Review (IP Section 03.06)

The inspectors reviewed the plant events listed below to determine if the event warranted the use of formal event review criteria and to evaluate the licensees response was in accordance with 10 CFR Parts 40.60 (source material), 70.50 (mainly radiological events),

70.52 (criticality and safeguards events), 71.95 (transportation events), 73.71 (safeguards events)) and 20.2201, 20.2202, and 20.2203 (radiological and environmental events):

NCS-2023-037, "NCS Safety Concern for Exceeding the 4-Tier Plate Rack Piece Count Limit," dated April 6, 2023 NCS-2023-052, "NCS Safety Concern for SFF Waste Discharge into Hot Waste Drains," dated June 6, 2023 NCS-2023-063, "NCS Safety Concern for HFIR Plates in Non-Fuel Storage Location in RTR," dated June 13, 2023 NCS-2023-067, "NCS Safety Concern for Hydraulic Leak in Jaw Crusher,"

dated June 22, 2023 NCS-2023-071, "NCS Safety Concern for Removal of High-Level Dissolver Filter," dated June 22, 2023 Audits (IP Section 03.07)

The inspectors reviewed the internal audit listed below to determine whether they have been performed in accordance with 10 CFR 70.22(h)(1) and the license application.

health physics audit 1st quarter 2023 dated March 31, 2023 Radiation Work Permit (IP Section 03.09)

The inspectors reviewed and observed the radiation work permit (RWP) listed below to determine whether the RWP contains the information required by chapter 4, "Radiation Safety," of the license application, the radiation protection manual, and implementing procedures:

RWP 23-0034, "Clean Bay 12A Saw to Decontaminate in Order to Support Return to Operation," conducted on May 17, 2023 88135.04 - Resident Inspection Program Operational Safety The inspectors evaluated whether the material condition and as-found configuration of selected site structures, systems, and components, documentation, personnel, and IROFS to verify compliance with 10 CFR 70, the license, the SAR and/or license application, and licensee policies and procedures; and determine whether they are appropriate, available, and reliable to protect worker and public safety during normal, off-normal, and accident conditions.

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Operations Safety Walkdown (IP Section 03.01)

The inspectors evaluated the operational safety of the systems and sub-systems of the listed processes associated with SAR 15.28, "Metallographic Laboratories."

observed the operation of the hot side saw.

compared met lab storage racks with design drawings.

observed operations in the met lab.

reviewed NCS technical work records.

observed cleanout of the met lab sludge tank.

88135.05 - Resident Inspection Program Fire Protection (Annual/Quarterly)

The inspectors evaluated the operational status and material condition of fire protection systems, structures, and components to verify compliance with the fire protection program as described in chapter 7, "Fire Safety," of the license application, and the National Fire Protection Association 801, "Standard for Fire Protection for Facilities Handling Radioactive Materials," as required.

Fire Area Walkdown (IP Section 03.01)

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

bay 12A, recovery 88135.19 - Post Maintenance Testing The inspectors evaluated post-maintenance test activities to verify compliance with license application chapter 11, "Management Measures," and test procedures and/or WO instructions to confirm functional capability of the IROFS and/or safety controls following maintenance.

Post-Maintenance Testing (IP Section 03.01)

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

WO 20333897, oxygen sensor test on filler manufacturing lines #7 and

  1. 8 on May 1, 2023 WO 20347241, leak check of column contactor organic #1 on June 2, 2023 88135.22 - Surveillance Testing The inspectors evaluated IROFS and safety controls that required periodic surveillance and/or calibration tests to ensure they were available and reliable to perform their function when needed, to comply with license application chapter 11, "Management Measures," and the performance requirements of 10 CFR 70.61 and 70.62, and to maintain their operational readiness consistent with the integrated safety analysis.

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Surveillance and Calibration Testing (IP Section 03.01)

The inspectors reviewed the surveillance and/or calibration test listed below. Test was either observed directly or test results were reviewed.

shift inline monitor operation check for inline monitor #3 on May 17, 2023 INSPECTION RESULTS No issues were identified.

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

On June 30, 2023, the inspectors presented the integrated inspection results to James J.

Bittner and other members of the licensee staff.

On May 25, 2023, the inspectors presented the operation safety inspection results to James J. Bittner and other members of the licensee staff.

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DOCUMENTS REVIEWED Inspection Type Designation Description or Title Revision or Procedure Date 88020 Corrective Action CA202200509 Incident 03/29/2023 05/24/2023 Documents 88020 Corrective Action CA202200634 Incident 05/04/2022 05/24/2023 Documents 88020 Corrective Action CA202201581 Incident 11/22/2022 05/24/2023 Documents 88020 Corrective Action CA202201603 Incident 11/28/2022 05/24/2023 Documents 88020 Corrective Action CA202300078 Incident 01/23/2023 05/24/2023 Documents 88020 Corrective Action CA202300083 Incident 01/19/2023 05/24/2023 Documents 88020 Corrective Action CA202300136 Incident 02/06/2023 05/24/2023 Documents 88020 Corrective Action CA202300297 Incident 05/24/2023 05/24/2023 Documents 88020 Corrective Action CA202300632 Incident 05/22/2023 05/22/2023 Documents 88020 Corrective Action CA202300643 Incident 05/23/2023 05/24/2023 Documents 88020 Corrective Action CA202300645 Incident 05/24/2023 05/25/2023 Documents 88020 Engineering CHG-12205 Addition of Secondary Scrub Lines to Adequately Flush 03/10/2023 Changes Process Systems 88020 Engineering CHG-12348 Evaporator System Pressure Gauges MP Creation and 12/15/2022 Changes Drawing Update 88020 Engineering CHG-2545 Revise OPs 61121, 61123, and 61124 09/15/2022 Changes 88020 Engineering CHG-9650 Changes to SAR 15.09 and SAR Appendix 15.09 02/21/2022 Changes 88020 Engineering 95-00169-00 Fire Loading Calculation for Fire Area 13A-3 12/05/1995 Evaluations 10

Inspection Type Designation Description or Title Revision or Procedure Date 88020 Engineering 95-0038-00 Fire Loading Calculation for Fire Area 14A-1 01/03/1997 Evaluations 88020 Engineering 95-0058-00 Fire Loading Calculation for Fire Area 13A-2 07/05/1995 Evaluations 88020 Engineering HS 2022-020 Removal of Crediting Trained Operator Utilizing 02/01/2022 Evaluations Densitometers as an IROFS in SAR 15.09 88020 Engineering NCS-2004-069 Nuclear Safety Release Supporting Phase 5 of SER03-033, 03/24/2004 Evaluations Centrifugal Contactor System - Install Contactors and Other Equipment Necessary for the Contactor Operation,03-033 Phase 5 88020 Engineering NCS-2006-090 Nuclear Criticality Safety Release Supporting SAR 15.09 04/24/2006 Evaluations Cross Walk Revision 88020 Engineering NCS-2011-075 Nuclear Safety Release Supporting SER 10-032 (Primary 04/28/2011 Evaluations Condensate Annular Tank) 88020 Engineering NCS-2012-06 Drum Dryer Safety Release per SER 11-033 05/09/2012 Evaluations 88020 Engineering NCS-2019 -014 NCS Safety Release for a New Recovery Drum Dryer 02/01/2019 Evaluations System per SER 17-048 Phase 1 88020 Miscellaneous QWI 18.1.1 Safety Training Rev. 12 88020 Miscellaneous QWI 4.1.5 Design Criteria for NRC Licensed Activities Rev. 26 88020 Miscellaneous QWI 9.1.7 Preventive/Predictive Maintenance and Safety-Related Rev. 13 Controls Testing Program 88020 Miscellaneous TP-REC-0001 Introduction to Recovery Rev. 1 88020 Miscellaneous TP-REC-0002 Advanced Recovery Operator Functions Rev. 0 88020 Miscellaneous TP-REC-0007 Primary and Raffinate Extraction Area Rev. 1 88020 Miscellaneous TP-REC-0010 Drum Dryer Area Rev. 0 88020 Miscellaneous TP-REC-0012 Recovery Scrubber Rev. 0 88020 Procedures E61-019 Daily Uranium and Safety Inventory Checklist Form Rev. 14: May 2023 (Monthly) 88020 Procedures MP 1086 Quarterly Sampling of Cooling Water Discharge for U-235 03/13/2023, 11/11/2022 88020 Procedures MP 3161 Recovery Evaporators 1-6 Condenser and Heat Exchanger 01/31/2023, 1-3 Integrity Test 06/30/2022 11

Inspection Type Designation Description or Title Revision or Procedure Date 88020 Procedures MP 3163 Semi-Annual Pressure Testing-Steam Condensate Cooling 01/03/2023 Heat Exchangers 88020 Procedures MP 3346 Annual Replacement of the Pressure Relief Valve Serving 03/29/2023 Evaporator 1 88020 Procedures MP 3348 Annual Replacement of the Pressure Relief Valve Serving 03/29/2023, Evaporator 2 03/03/2022 88020 Procedures MP 3349 Annual Replacement of the Pressure Relief Valve Serving 03/29/2023, Evaporator 3 03/03/2022 88020 Procedures MP 3350 Annual Replacement of the Pressure Relief Valve Serving 03/29/2023, Evaporator 4 03/03/2022 88020 Procedures MP 3351 Annual Replacement of the Pressure Relief Valve Serving 03/29/2023, Evaporator 5 03/03/2022 88020 Procedures MP 3352 Annual Replacement of the Pressure Relief Valve Serving 03/29/2023, Evaporator 6 03/03/2022 88020 Procedures MP 3366 Evaporators 1-6 Heat Exchanger Integrity Test 02/07/2023, 08/02/2022 88020 Procedures MP 4191 Spare Organic Tank High-Level Switch Check 06/01/2022, 11/30/2022 88020 Procedures MP 4193 Organic Tank High-Level Switch Check 06/01/2022, 11/30/2022 88020 Procedures MP 5146 Quarterly Sampling of Cooling Water Discharge for U-235 12/15/2022 88020 Procedures OP-0000272 Liquid Handling at the Retention Tank In-Line Monitor Rev. 9 System 88020 Procedures OP-0061121 Primary Evaporator System Rev. 33 88020 Procedures OP-0061123 Contactor Evaporator System Rev. 27 88020 Procedures OP-0061124 Evaporator #6 Operation Rev. 19 88020 Procedures OP-0061129 Drum Dryer Collection of Uranyl Nitrate Crystals Rev. 59 88020 Procedures OP-0061161 Operating Procedure for Training of Uranium Processing Rev. 11 Operators 88020 Procedures OP-0061234 Performing Maintenance in UPRR Rev. 60 88020 Procedures QWI 14.1.01 Preventive/Corrective Action System (U) Rev. 43 88020 Procedures QWI 17.1.02 Internal Quality Audits Rev. 23 88020 Radiation Work 23-0012 Flush Recovery HF Line per OP-1018680 Rev. 00 Permits (RWPs) 12

Inspection Type Designation Description or Title Revision or Procedure Date 88020 Self-Assessments IA-2572B-2022- June 2022 06-01 88020 Self-Assessments IA-2572C-2022- Nov. - Dec.

07-01 2022 88020 Self-Assessments IA-258-3A-2022- May-June 05-01 2022 88020 Self-Assessments IA-2583J-2022- Dec. 2022 12-01 88020 Work Orders 20334943 Quarterly Sampling of Cooling Water Discharge for U 235 04/07/2023 88020 Work Orders 20335407 Semi-Annual Pressure Testing- Steam Condensate Cooling 06/30/2022 Heat Exchangers 88020 Work Orders 20343713 SC DDRY COL HL SEN 1 YURPSM/RECO 05/01/2023 88135.02 Corrective Action CA202300401 Regulatory - NCS violation 04/05/2023 Documents 88135.02 Corrective Action CA202300610 Safety near hit RP - UIR 05/02/2023 Documents 88135.02 Corrective Action CA202300638 NCS -UIR 05/23/2023 Documents 88135.02 Corrective Action CA202300643 NCS-UIR 05/23/2023 Documents 88135.02 Corrective Action CA202300683 Compliance with instruction 06/01/2023 Documents 88135.02 Corrective Action CA202300703 Work instruction incomplete/incorrect 06/02/2023 Documents 88135.02 Corrective Action CA202300711 NCS-UIR 06/07/2023 Documents 88135.02 Corrective Action CA202300761 UIR-NCS 06/18/2023 Documents 88135.02 Corrective Action CA202300769 NCS-UIR 06/20/2023 Documents 88135.02 Corrective Action CA202300771 NCS-UIR 06/21/2023 Documents 88135.02 Engineering NCS-2023-037 NCS Safety Concern for Exceeding the 4-Tier Plate Rack 04/06/2023 Evaluations Piece Count Limit 13

Inspection Type Designation Description or Title Revision or Procedure Date 88135.02 Engineering NCS-2023-052 NCS Safety Concern for SFF Waste Discharge into Hot 06/06/2023 Evaluations Waste Drains 88135.02 Engineering NCS-2023-063 NCS Safety Concern for HFIR Plates in Non-Fuel Storage 06/13/2023 Evaluations Location in RTR 88135.02 Engineering NCS-2023-067 NCS Safety Concern for Hydraulic Leak in Jaw Crusher 06/22/2023 Evaluations 88135.02 Engineering NCS-2023-071 NSC Safety Concern for Removal of High-Level Dissolver 06/22/2023 Evaluations Filter 88135.02 Miscellaneous N-554 Critique meeting minutes for CA202300703 06/07/2023 88135.02 Miscellaneous N/A Annual contractor's seminar 06/15/2023 88135.02 Miscellaneous N/A 2022 ALARA Report 06/05/2023 88135.02 Miscellaneous RP-13-003, form Health Physics Audit Rev. 14 2

88135.02 Procedures N-50 Employee Review of Area Documents Rev. 8 88135.02 Procedures N-79 Evaluation of Unusual Incidents Rev. 11 88135.02 Procedures OP-0061167 Operating Procedure for Spill and Leak Handling Emergency Rev. 36 Procedure 88135.02 Procedures OP-0061450 Operating Procedure for General Safety and Safeguards Rev. 40 Guidelines - UPRR Area 88135.02 Procedures QWI 14.1.14 Conducting Critique Meetings Rev. 12 88135.02 Radiation Work 23-0034 Clean Bay 12A Saw to Decontaminate in Order to Support a Rev. 00 Permits (RWPs) Return to Operation for "Cold" Material, Repackage Waste Drums 88135.02 Self-Assessments N-50 Employee review of area documents 05/25/2025 88135.04 Drawings LP-4153E Anocut Saw Filter System 04/02/1990 88135.04 Drawings LT-3725E Element Rack for Met Lab Lift or Wall Mount Rev. 0 88135.04 Drawings LT-4428 Met Lab Fuel Storage Cabinet Rev. 2 88135.04 Engineering NCS-1989-305 Anocut Saw Filtration System 11/07/1989 Evaluations 88135.04 Engineering NCS-2000-256 NCS Evaluation for Replacement of Met Lab Hot Saw per 09/20/2000 Evaluations SER-00-062 88135.04 Procedures OP-1003449 Control of Fuel Residue in Met Lab Preparation Rooms Rev. 6 88135.04 Procedures OP-1004709 Operation of Savage Hot Side Saw Rev. 13 88135.05 Fire Plans Section 13C Bay 12A 01/15/2021 14

Inspection Type Designation Description or Title Revision or Procedure Date 88135.19 Procedures E61-648 UPRR Maintenance Work Request Form Rev. 5 88135.19 Procedures E61-691 Checklist for UPRR Maintenance Work Order Assessment Rev. 3 88135.19 Procedures E61-692 Pressurized Piping and Leak Test Record Rev. 1 88135.19 Procedures N-307 Lockout/Tagout Permit Rev. 2 88135.19 Procedures N-350 Industrial Engineering Work Request Rev. 11 88135.19 Procedures OP-1003724 Filler Manufacturing Operations Areas Safety Controls Rev. 35 88135.19 Work Orders 20333897 SC Oxygen Sensor 02M110 9MON PAMET 05/01/2023 88135.19 Work Orders 20347241 Replace Contactor Organic Columns 1 & 2 06/02/2023 88135.22 Procedures E61-644 Shift Inline Monitor Operation Check Rev. 4 88135.22 Procedures OP-0061242 Operating Procedure for Inline Monitor System Rev. 40 15