ML23292A125

BWXT Nuclear Operations Group, Inc. - Integrated Inspection Report 07000027/2023003

ML23292A125
Person / Time
Site:	BWX Technologies
Issue date:	10/25/2023
From:	Eric Michel NRC/RGN-II/DFFI
To:	Bittner J BWXT
References
IR 2023003
Download: ML23292A125 (1)

Text

October 25, 2023 James J. Bittner, Vice President and General Manager Nuclear Operations Group, Inc.

BWXT Nuclear Operations Group, Inc.

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

SUBJECT:

BWXT NUCLEAR OPERATIONS GROUP, INC. - INTEGRATED INSPECTION REPORT 07000027/2023003

Dear James J. Bittner:

This letter refers to the U.S. Nuclear Regulatory Commission (NRC) inspection activities conducted from July 1, 2023, to September 30, 2023, for the BWXT Nuclear Operations Group, Inc., facility. On October 12, 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 10/25/23 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

ML23292A125 Non-Sensitive Publicly Available X SUNSI Review Sensitive Non-Publicly Available OFFICE R2/DFFI R2/DFFI NAME N. Peterka E. Michel DATE 10/24/2023 10/25/2023 U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number: 07000027 License Number: SNM-42 Report Number: 07000027/2023003 Enterprise Identifier: I-2023-003-0060 Licensee: Nuclear Operations Group, Inc.

Facility: BWXT Nuclear Operations Group, Inc.

Location: Lynchburg, VA 24505 Inspection Dates: July 1, 2023, to September 30, 2023 Inspectors: M. Doyle, Senior Resident Inspector C. Oelstrom, Fuel Facilities Inspector N. Peterka, Sr. Fuel Facility L. Pitts, Sr. Fuel Facility Inspector T. Sippel, Sr. Fuel Facility Inspector G. Wertz, Project Manager 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 Type Issue Number Title Report Section Status NOV 07000027/2020004-01 Failure to Perform Post- 88015 Closed Maintenance Testing of Primary Condensate Tank Inline Monitor #2 2

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 88015 - Nuclear Criticality Safety The inspectors evaluated selected aspects of the licensee's 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, 70.50, 70.61, 70.62, and appendix A; chapter 5, "Nuclear Criticality Safety," of the facilitys license application; and applicable licensee procedures.

Criticality Analysis (IP Section 02.01)

The inspectors interviewed licensee staff and reviewed nuclear criticality safety evaluations (NCSEs) and associated assumptions and calculations to verify compliance with 10 CFR 70 and applicable sections of the license application including portions of 5.2. Specifically, the inspectors interviewed licensee staff and reviewed the following:

• NCS-PA-27-00001, "Nuclear Criticality Safety Evaluation of the NR Element Immersion Operations," Revision (Rev.) 1, including the review of accident sequences EL7E-23, EL7E-26, and EL7E-29 which cover various immersion accident scenarios and reviewing the basis for why the licensee screened certain accident sequences as not credible

• NCS-PA-26-00001, "Nuclear Criticality Safety Process Analysis of the Conventional Fuel Pack Assembly Process," Rev. 1, including the review of what-if analysis, normal, credible abnormal, and non-credible accident sequences

• NCS-TR-00054, "Nuclear Safety Technical Reference for NR Element Immersion Operations", Rev. 1, which was reviewed because it contained a variety of calculations and information supporting the licensee's evaluation of criticality accident sequences in NCS-PA-27-00001 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 operator interviews to verify compliance with 10 CFR 70 and applicable sections of the license application including chapter 11, Management Measures. Specifically, the inspectors interviewed licensee staff and reviewed the following controls:

• passive engineered piece count control items relied on for safety (IROFS) for higher tier components in bay 8

• administrative piece count and spacing controls IROFS for higher tier components in bay 8

• administrative spacing and geometry control IROFS in UR

• administrative concentration and mass control IROFS in the retention tank building

• passive engineered and administrative moderation control IROFS in the RTR UAlx glovebox and associated NCS postings and operating procedures

• performed walkdowns in UR, RTR area, filler, the retention tank building, and other fuel handling areas

• reviewed relevant portions of the ISA including safety analysis report (SAR) 15.37, "Higher Tier Assemblies" 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:

• reviewed NCS safety training 2023

• reviewed 2023 NCS refresher records and 2022 and 2023 training completion records

• interviewed retention tank operator and NCS engineer concerning criticality hazards and control methods for the retention tanks including monitoring for long-term accumulations

• observed a licensee NCS engineer conduct a weekly inspection in bay 8 and reviewed recent NCS audit reports

• interviewed bay 8 operators concerning criticality hazards and control methods including the use of administrative and active engineered controls used during operations 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:

• reviewed procedure NCSE-02, "Nuclear Criticality Safety Analyses and Quality Assurance Reviews," Rev. 51 4

• reviewed procedure NCSE-03, "Nuclear Criticality Safety Audits and Inspections", Rev. 31, to determine the required content for NCS inspections and audits

• reviewed NCS weekly inspections report forms for various process areas and controls

• reviewed audits, inspections, and observations summary 1st and 2nd quarter reports

• reviewed various NCS engineer training and qualification records and reviewed work products by qualifying NCS engineers Criticality Incident Response and Corrective Action (IP Section 02.05)

The inspectors reviewed the licensees criticality accident alarm system and corrective action program (CAP) to verify compliance with 10 CFR 70 and applicable sections of the license application including 11.6. Additionally, the inspectors followed up on notice of violation (NOV) 07000027/2020004-01, "Failure to Perform Post-Maintenance Testing of Primary Condensate Tank Inline Monitor #2." Specifically, the inspectors:

• reviewed recent NCS-related CAP entries including corrective actions (CAs)

CA202201292, CA202300401, CA202300638, CA202300710, CA202300761, and CA202300868

• reviewed recent NCS safety concerns that evaluated selected events including NCS-2023-037, NCS Safety Concern for Exceeding the 4-Tier Plate Rack Piece Limit, which evaluated an event in which too many RTR fuel plates were stored on a rack

• interviewed licensee staff and reviewed NCS evacuation drill records from 2022 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.

• observed shutdown activities during the week of July 3, 2023

• observed the initial coating of tri-structural isotropic fuel on August 8, 2023

• observed the day and afternoon shift evacuation drills on September 28, 2023 5

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 as low as reasonably achievable meeting on July 27, 2023

• attended change review board meetings on July 12, August 10, and August 18, 2023

• met with nuclear safety review board on August 3, 2023 Record and Log Reviews (IP Section 03.03)

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

• second quarter 2023 audit of environmental engineering

• second quarter 2023 audit of industrial health and safety

• second quarter 2023 audit of radiation protection

• second quarter 2023 audit of criticality safety

• second quarter 2023 audit of licensing and safety analysis 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.

• CA202300907, incident date July 19, 2023

• CA202300868, incident date July 21, 2023

• CA202300944, incident date August 8, 2023

• CA202300968, incident date August 14, 2023

• CA202301041, incident date August 24, 2023

• CA202301064, incident date August 31, 2023

• CA202301091, incident date September 6, 2023

• CA202301169, incident date September 6, 2023

• CA202301154, incident date September 7, 2023

• CA202301121, incident date September 13, 2023

• CA202301189, incident date September 25, 2023 6

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 23-0054, "Operate SFF Inline in Bypass," Rev. 00, on August 15, 2023 Annual Security and Emergency Preparedness Drills/Exercises (IP Section 03.10)

The inspectors observed the licensees performance during the security force-on-force (FOF) tactical response exercise and emergency plan drill listed below to determine they were being implemented in accordance with 10 CFR 70.22(I)(3) and/or 10 CFR 73.46(b)(9):

• security FOF tactical response exercise conducted on August 23, 2023

• observed an emergency plan drill conducted on September 20, 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.

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 the following operation areas:

SAR 15.29, "Chemistry Laboratory", Rev. 31

• walkdown of IROFS

• observed daily startup checks of the dilution column inline monitor 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 (SSCs) to verify compliance with the fire protection program as described in chapter 7, "Fire Safety" of the license application, and the National Fire Protection Association (NFPA) 801, "Standard for Fire Protection for Facilities Handling Radioactive Materials," as required. Also, the inspectors evaluated onsite fire brigade training and drill performance to verify compliance with the license application and NFPA 600, "Standard on Industrial Fire Brigade."

Fire Area Walkdown (IP Section 03.01)

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

• bays 1A, 2A, and 3A (checkpoint #2) 7

Fire Brigade Drill Performance Sample (IP Section 03.02)

The inspectors evaluated the fire brigade training described below:

• the inspectors observed fire station 18 training conducted on September 9 and September 23, 2023, and observed both classroom and practical training sessions for performing high-angle rope rescues and practiced responding to medical emergencies involving severe injuries 88135.19 - Post-Maintenance Testing The inspectors evaluated post-maintenance test activities to verify compliance with license application chapter 11, "Management Measures," and test procedures and/or work order (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 test listed below. Tests were either observed directly or test results were reviewed.

• WO 20349887, rotometer module on inline #1 conducted on July 21, 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, and the performance requirements of 10 CFR 70.61 and 70.62, and to maintain their operational readiness consistent with the ISA.

Surveillance and Calibration Testing (IP Section 03.01)

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

• annual fire hydrant testing and maintenance conducted on July 3, 2023

• oxygen monitor for highly enriched uranium (HEU) power blender glove box

1. 2 conducted on August 30, 2023

• chemistry laboratory thermo-eberline system, daily startup checks of the chemistry laboratory waste dilution column, and inline monitor conducted on September 20, 2023 8

FACILITY SUPPORT 88070 - Permanent Plant Modifications The inspectors conducted a review to verify the licensee had established and implemented a configuration management system to evaluate, implement, and track changes to the facility in accordance with the applicable requirements in 10 CFR 70.72 and license application chapter 11. The inspectors review also verified the licensee had established management measures for changes to the facility in accordance with 10 CFR 70, subpart H, and the license application and that modifications involving new processes met the requirements in 10 CFR 70.64.

Sample Selection (IP Section 02.01)

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

• SER 11618, "Changes to SAR 15.38, SAR Appendix 15.38, SAR 15.42, and SAR Appendix 15.42," (core assembly, disassembly, and storage)

• SER 11983, "Update to SAR 15.20 per NCS-2022-009 Appendix B," required due to changes to the 235U counting process in nuclear material control operations

• SER 12303, "Update to SAR 15.18 per NCS-2021-111"

• SER 18-034 Phase 2, "Integrate Furnace & Glove Box at LTC Building B,"

integration of existing Centorr hydrogen furnace with new equipment and systems

• SER 20-039 Phase 7, "Storage of Uranium Feedstock in the Bay 13A Compacting Area"

• SER 21-014 Phase 1, "Upgrade LTC Physical Vapor Deposition Coater to Handle Enriched Uranium" Facility Change/Modification Process (IP Section 02.02)

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

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

o quality work instruction (QWI) 02.1.02, "Preparation and Maintenance of Safety Analysis Reports (SARs)," Rev. 19 o QWI 5.1.7, "Safety Analysis Requests," Rev. 38 o QWI 5.1.12, "Change Management," Rev. 38 o QWI 5.1.20, "Change Review Board," Rev. 11 o QWI 9.1.7, "Preventive/Predictive Maintenance and Safety-Related Controls Testing Program," Rev. 13 9

• interviewed licensee staff, performed walkdowns of bay 13A compacting area and Lynchburg Technology Center (LTC), and reviewed the following configuration management packages to verify the licensees evaluation of changes provided valid technical bases to determine whether an amendment to the license was required based on the criteria in 10 CFR 70.72(c):

o SER 18-034 Phase 2 o SER 20-039 Phase 7 o SER 21-014 Phase 1

• reviewed facility documentation associated with the selected changes to verify the affected documents were updated promptly in accordance with 10 CFR 70.72(e) or the timeframe outlined in the license

• reviewed configuration management system records to verify the licensee submitted a summary with facility changes and revised ISA summary pages to the NRC in accordance with 10 CFR 70.72(d)

Management Measures (IP Section 02.03)

For the selected modifications, the inspectors reviewed the management measures established for affected IROFS (or credited safety controls) to verify the management measures were available and reliable to perform their intended function as required by 10 CFR 70.61 and the license application. Specifically, the inspectors conducted the inspection activities listed below:

• interviewed licensee staff and reviewed change management procedures to verify the licensee implemented the aspects described in configuration management system procedures and the license application

• interviewed licensee staff and reviewed affected procedures to verify the licensee followed the procedure control process in accordance with the license

• interviewed licensee staff responsible for determining the post-maintenance testing requirements for the selected SER 18-034 Phase 2, SER 20-039 Phase 7, and SER 21-014 Phase 1

• reviewed SER 21-014 Phase 1 post-modification requirements and interviewed the licensee staff responsible for developing and performing those post-modification tests

• interviewed licensee staff and reviewed training records to verify the staff involved in facility changes were qualified in accordance with the license and plant procedures

• interviewed licensee staff and reviewed training records to verify the licensee conducted training on plant modifications in accordance with the license application and plant procedures

• reviewed CA documents to determine whether the licensee identified configuration management, post-modification testing, and/or plant modification issues and corrected the condition in accordance with approved CAP procedures and the license

• reviewed recent audits and assessments of the configuration management system and interviewed licensee staff to verify the scope and frequency of audits were being conducted in accordance with the license application and facility procedures 10

License Application Changes (IP Section 02.04)

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

• reviewed the licensees procedures QWI 5.1.12 and QWI 5.1.20 used to determine whether NRC pre-approval of license application changes was required to verify that the licensee's process for evaluating license application changes was in accordance with license and regulatory requirements

• interviewed licensee staff responsible for performing 10 CFR 70.72 change evaluations and reviewed ISA reviewer change evaluation forms in which the licensee documents the license application change evaluations associated with selected changes listed below to verify the licensee maintained records of the evaluations and provided the bases for determining the change did not require prior NRC approval including:

o N-517, 10 CFR 70.72 Change Evaluation Checklist for SER 11618, Changes to SAR 15.38, 15.42, and 15.42 Appendix o N-517, 10 CFR 70.72 Change Evaluation Checklist for SER 11983, Update to SAR 15.20 per NCS-2022-009 Appendix B, required due to changes to the 235U counting process in NMC operations o N-517, 10 CFR 70.72 Change Evaluation Checklist for SER 12303, Update to SAR 15.18 per NCS-2021-111 New Processes at Existing Facilities (IP Section 02.05)

The licensee had not implemented any new facility processes at the time of the inspection.

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

Records Retention (IP Section 02.06)

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

• SAR and SAR appendices including, SAR 15.18, SFF Dry-End Processing SFF Operation, SAR 15.20, U-235 Counting Process in NMC Operations, SAR 15.38, Core Assembly, Disassembly, and Railyard Storage, and SAR 15.42, Container Storage Facility

• license application 11

INSPECTION RESULTS NOV Failure to Perform Post Maintenance Testing of Primary 88015 Condensate Tank Inline Monitor #2 NOV 07000027/2020004-01

Description:

This violation was opened in NRC integrated inspection report 70-27/2020-004 (ML21029A157). During this inspection, the inspectors reviewed licensee CAP entry CA 2020-1545 which documented licensee short-term and long-term CAs resulting from the violation. The licensee took CAs to properly test the functionality of the affected inline monitor IROFS, restoring compliance on October 23, 2020. Additionally, the licensee completed (1) an extent-of-condition review to identify other programmable logic controller (PLC)-driven IROFS and implement measures to ensure they are not adversely affected by PLC-related maintenance, (2) revised QWI level guidance to aid in defining safety class B control boundaries (both IROFS and non-lROFS), and (3) providing criteria for completion of post-maintenance testing to verify the functionality of the affected control.

Considering this review and reviews conducted previously by the senior resident inspector at BWX Technologies, Inc., the inspectors have determined that the licensee has completed their CAs as documented in CA 2020-1545. This item is closed.

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

• On August 17, 2023, the inspectors presented the NCS inspection results to David Spangler and other members of the licensee staff.

• On September 14, 2023, the inspectors presented the annual plant modifications inspection results to Richard Freudenberger and other members of the licensee staff.

• On October 12, 2023, the inspectors presented the integrated inspection results to James Bittner 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 CA201800561 NCS-related CAP entries Various Documents CA202201292 CA202300401 CA202300638 CA202300710 CA202300761 CA202300868 Engineering CHG-00009427 Move Three-Way Valve to New PLC Output 12/03/2020 Changes CHG-00011622 Revision of QWI 09.1.07 to Include Post-Maintenance 05/23/2022 Testing Requirements for Safety Class A and B Controls Engineering NCS-2023-037 NCS Safety Concern for Exceeding the 4-Tier Plate Rack 04/06/2023 Evaluations Piece Limit NCS-2023-054 NCS Safety Concern for the Improper Loading of Material in 06/14/2023 the High-Level Dissolver Trough #1, per CA202300638 NCS-2023-064 NCS Safety Concern for the Abnormal Interspersed 06/27/2023 Moderation on the Transient/Floor Storage Array near LLD per CA202300710 NCS-2023-067 NCS Safety Concern for Hydraulic Leak in Jaw Crusher per 06/22/2023 CA202300761 NCS-2023-085 NCS Safety Concern for the Failed Reference Check 08/10/2023 Inspection of the Inline Monitor #1 per CA202300868 NCS-PA Nuclear Criticality Safety Process Analysis of the Rev. 1 00001 Conventional Fuel Pack Assembly Process NCS-PA Nuclear Criticality Safety Evaluation of the NR Element Rev. 1 00001 Immersion Operations (U)

NCS-PA Nuclear Criticality Safety Process Requirements Document Rev. 0 00005 for NCS-PA-30-00005 NCS-TR-00054 Nuclear Criticality Safety Technical Reference for NR Rev. 1 Element Immersion Operations (U)

SAR15.37 Higher Tier Assemblies Rev. 145 Miscellaneous Various NCS engineer training and qualification records Various 2023 NCS Training 13

Inspection Type Designation Description or Title Revision or Procedure Date 2023 NCS Refresher Training 2022 Evacuation Drill Results 10/07/2022 2022 Annual Evacuation Drill and Tornado Alarm Sounding 08/15/2022 Evacuation Field Layout 08/22/2022 Training completion records for NCS refresher 2023 and 2022 MP-3168 Primary Condensate Tank Inline #2 Alarm Monthly Test NCS-TR-00007 Validation Report for SCALE 6.1 Rev. 05 Q38-0319 Quarterly Inspection of PLC Crane Controls Rev. 4 Procedures E61-648 UPRR Maintenance Work Request Form Rev. 5 E61-691 Checklist for UPRR Maintenance Work Order Assessment Rev. 3 NCSE-02 Nuclear Criticality Safety Analyses and Quality Assurance Rev. 51 Reviews OP-0006506 Crushing and Blending UAlx Rev. 15 OP-0061234 Maintenance in UPRR Rev. 60 OP-1046055 BR2 Crushing and Blending UAlx Rev. 3 POSTING 15 RTR Four-Tier Plate Rack Rev. 00 059 QWI 9.17 Preventive/Predictive Maintenance and Safety-Related Rev. 13 Controls Testing Program Self-Assessments Various weekly NCS inspection reports Varies NCS-2023-043 Audits, Inspections, and Observations Summary - 1st 04/17/2023 Quarter 2023 NCS-2023-077 Audits, Inspections, and Observations Summary - 2nd 07/26/2023 Quarter 2023 Work Orders 20292831 REPLACE CHASSIS PRI EXTRACTION PLC 10/22/2020 20349425 SC PRI COND TK INLINE #2 ALARM 1M RECO 08/09/2023 88070 Corrective Action CA202201264 Part A requirements of SER 20-015 Phase 1 were not signed 09/14/2022 Documents off and/or met prior to releasing glovebox WS 330 north to operation CA202300324 Incorrect management measure cited in SAR 03/17/2023 CA202300848 Change management process not used when required 06/15/2023 CA202300886 Before returning a HVAC system to service, it was identified 07/20/2023 14

Inspection Type Designation Description or Title Revision or Procedure Date that the system had not been modified as required by the SER Engineering SER 11618 Changes to SAR 15.38, SAR Appendix 15.38, SAR 15.42, 01/31/2022 Changes and SAR Appendix 15.42 SER 18-034 Integrate Furnace and Glove Box at LTC Building B 01/09/2023 Phase 02 SER 20-039 Storage of Natural Uranium Feedstock in Bay 13A 11/15/2022 Phase 07 SER 21-014 Upgrade LTC Physical Vapor Deposition Coater to Handle 09/17/2023 Phase 01 Enriched Uranium SER-11983 Changes to SAR 15.20 and SAR Appendix 15.20 04/18/2022 SER-12303 Changes to SAR 15.18 per SER 21-026 03/23/2022 Procedures QWI 02.1.02 Preparation and Maintenance of Safety Analysis Reports Rev. 19 QWI 02.1.03 Integrated Safety Analysis Methodology Rev. 18 QWI 5.1.12 Change Management Rev. 38 QWI 5.1.12 ATT. Risk Level Definition Rev. 21 01 QWI 5.1.20 Change Review Board Rev. 11 QWI 5.1.7 Safety Evaluation Requests Rev. 38 QWI 9.1.7 Preventive/Predictive Maintenance and Safety-Related Rev. 13 Controls Testing Program Self-Assessments IA-SAR-2022 Audit of SAR 15.22 - RTRT Fuel Powder and Compact 12/2022 01 Processes IA-SAR-2023 Audit of SAR 15.27 - NR Fuel Element Fabrication Process 03/2023 01 88135.02 Corrective Action CA202300944 RP-UIR 08/08/2023 Documents CA202301059 Filler Fabrication 08/17/2023 Engineering NCS-2023-070 NCS Safety Concern for ATR Plate on Non-Fuel Workstation 07/10/2023 Evaluations in RTR NCS-2023-076 NCS Safety Concern Analysis for CA202300775 07/11/2023 NCS-2023-092 NCS Safety Concern for CA202301041 08/30/2023 Miscellaneous N/A Recovery return to work 05/01/2023 Procedures E41-206 Nuclear Materials Control Accountability Operations Rev. 03 15

Inspection Type Designation Description or Title Revision or Procedure Date NCS-09 Leaks, Spills, and Floor Scrubbing Rev. 07 OP-0061167 Spill and Leak Handling Emergency Procedure Rev. 36 OP-1001832 Operating Procedure for SSF Low-Level Waste System No. Rev. 25 2

Radiation Work RWP 23-0054 Operate SFF Inline in Bypass Rev. 00 Permits (RWPs) 88135.05 Miscellaneous HS-ET-001 Att. 1 Emergency Team Training Critique Rev. 13 88135.19 Work Orders 20349887 Fix rotometer module on inline #1 07/21/2023 88135.22 Miscellaneous Q2-206 Dilution Column Dumping Accountability Rev. 03 Procedures HS-FP-007 Fire Hydrant Testing and Maintenance Rev. 006 HS-FP-008 Industrial Health & Safety Operating Procedures Rev. 022 HS-FP-020 Five-Year Testing of the Fire Loop Rev. 008 OP-1004605 Operating Procedure for Operation of the Chemistry Lab Rev. 8 Waste Column and Inline Monitor Work Orders 20348784 Monitor, O2 HEU powd blender g. box #2 08/30/2023 16