ML23302A003

Nuclear Fuel Services, Inc. Core Inspection Report 07000143/2023003

ML23302A003
Person / Time
Site:	Erwin
Issue date:	11/02/2023
From:	Michael Greenleaf NRC/RGN-II/DFFI
To:	Dailey R Nuclear Fuel Services
References
IR 2023003
Download: ML23302A003 (1)

Text

Mr. Ronald Dailey President Nuclear Fuel Services, Inc.

P.O. Box 337 MS 123 Erwin, TN 37650-0337

SUBJECT:

NUCLEAR FUEL SERVICES (NFS), INC. - CORE INSPECTION REPORT 07000143/2023003

Dear Mr. Dailey:

On September 30, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Nuclear Fuel Services (NFS), Inc. The NRC inspectors discussed the results of this inspection with you and other members of your staff on July 20th, September 21st, September 28th, and October 16, 2023. 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, Michael Greenleaf, Acting Chief Projects Branch 1 Division of Fuel Facility Inspection Docket No. 07000143 License No. SNM-124

Enclosure:

As stated cc w/ encl: Distribution via LISTSERVNovember 2, 2023 Signed by Greenleaf, Michael on 11/02/23

ML23302A003 Non-Sensitive Publicly Available SUNSI Review Sensitive Non-Publicly Available OFFICE RII/DFFI RII/DFFI RII/DFFI RII/DFFI RII/DFFI RII/DFFI RII/DFFI

NAME L. Harris L. Cooke G. Goff P. Startz N. Peterka L. Pitts J. Grice DATE 10/30/2023 10/30/202310/30/2023 10/30/2023 10/30/2023 10/31/2023 10/30/2023

OFFICE RII/DFFI

NAME M. Greenleaf

DATE 11/02/2023

U.S. NUCLEAR REGULATORY COMMISSION Inspection Report

Docket Number: 07000143

License Number: SNM-124

Report Number: 07000143/2023003

Licensee: Nuclear Fuel Services, Inc.

Facility: Nuclear Fuel Services (NFS), Inc.

Location: Erwin, TN

Inspection Dates: July 01, 2023, to September 30, 2023

Inspectors: L. Cooke, Fuel Facility Inspector G. Goff, Fuel Facilities Inspector J. Grice, Fuel Facilities Inspector L. Harris, Senior Resident Inspector N. Peterka, Sr. Fuel Facility Project Inspector L. Pitts, Sr. Fuel Facility Projects Inspector J. Raudabaugh, Fuel Facility Inspector P. Startz, Fuel Facilities Inspector

Approved By: Robert Mathis, III, Chief Projects Branch 1 Division of Fuel Facility Inspection

Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a core inspection at Nuclear Fuel Services (NFS), 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.

2 PLANT STATUS

The following facility process areas were operating during the inspection period: Fuel Manufacturing Facility (FMF) and the Blended Low Enriched Uranium (BLEU) Preparation Facility (BPF), which includes the Uranium-Oxide (U-Oxide), solvent extraction and the down blending lines. Normal support services and departments were operational during the inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Inspections were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2600, Fuel Cycle Facility Operational Safety and Safeguards Inspection Program. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

SAFETY OPERATIONS

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), including sections 70.24, 70.61, and 70.62; Chapter 11, Management Measures, of the facilitys license application, and applicable licensee procedures.

Identification of Safety Controls and Related Programs (IP Section 02.01)

The inspectors selected specific process areas for inspection based on the safety basis information of the facility, the risk/safety significance of the process areas, the description of plant changes submitted to the NRC, and past plant performance documentation. For the process areas of interest, the inspectors selected a sample of accident sequences in nuclear criticality safety (NCS), radiation safety, fire safety, and chemical safety based on the information provided in the integrated safety analysis (ISA) summary. The process areas and accident sequences selected for review are listed below. The inspectors also conducted a general plant tour of each major plant operating area.

• Area 600 NCS-Related Accident Sequences o 4.1.1.1.a.1 and 2 involving spills of uranium in glovebox 0601 o 4.1.1.1.b.1 and 2 involving spills of uranium in glovebox 0602 o 4.1.1.1.c involving spills of uranium in glovebox 0603 o 4.1.1.1.d involving spills of uranium in glovebox 0604 o 4.1.1.4.a involving spills of uranium in the furnace tray path o 4.1.1.4.b involving spills of uranium in the furnace elevator housing o 4.1.2.1.a involving spills of uranium to glovebox 0601 and 0602 o 4.1.2.1.b involving spills of uranium to glovebox 0601 and 0602

3

• Area 600 Fire Safety-Related Accident Sequences o FRE-05d1, involving gas release via FLAREX-0601 o FRE-09d2, involving gas release via FLAREX-0602 o FRE-09d3, involving gas release from discharge chamber o FRE-09d4, involving gas release from connections and welds o FRE-09d5, involving high gas supply line pressure

• Area 600 PSL Furnace o EXP-PRE-001, involving accumulating combustible gases, evaluated by fire risk evaluations FRE05c and FRE05d o EXP-PRE-002, involving accumulating combustible gases, evaluated by FRE05d o FRE-09d1, involving combustible gas mixture not burned o FRE-09d5, involving combustible gas mixture released o FRE-09d7, involving combustible gas supply line pressure

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. 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:

• Production Area 600 - NCS-Related IROFS:

o FA6-001, administrative control for number of bottles in enclosure 0601 o FA6-002, administrative control for number of bottles in enclosure 0602 o FA6-003, administrative control for spilled tray logs o FA6-004, passive engineered control for dike around furnace and elevator pit o FA6-005, active engineered control spring return valve closure for enclosure 0601/0602 o FA6-006, administrative control manual valve closure after material transfer o FA6-007, administrative control number of bottles in enclosure 0603 o FA6-017, administrative control limit on liquids in enclosure 0603 o FA6-018, administrative control limit on bottles in enclosure 0604 o FA6-019, administrative control limit on liquids in enclosure 0604 o FA6-020, administrative control limit on liquids in enclosure 0602 o FA6-022, administrative control on weight loaded into trays o FMF-002, administrative control, hand carried container spacing

• Production Area 600 - Fire Safety IROFS:

o FIRE6-8, administrative control discharge chamber purged o FIRE6-10, administrative control furnace purge

4 o FIRE6-11, administrative control independent purge cycle verification o FIRE6-12, administrative control, startup leak test

• Production Area 600 - PSL Furnace IROFS:

o FIRE6C-002, combustible gas detection and shutdown o FIRE6C-019, redundant igniters o FIRE6C-030, shutoff valves o FIRE6C-046, detection of high gas pressure

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 walk-downs of the Area 600 and PSL furnaces

• reviewed samples of NCS postings and station limit cards around furnaces

• reviewed samples of Area 600 Nuclear Criticality Safety Evaluations (NCSEs)

• reviewed Letter of Authorization Operation for Unloading Area 600, 302 Furnace Post Event 92306

• reviewed samples of operating procedures for Area 600, PSL, and Area 700 to verify IROFS implementation

• reviewed Fire Risk Evaluations for Area 600

• interviewed NCS staff and reviewed ISA risk assessment procedure related to risk index scoring and independence of administrative controls

• reviewed spilled tray log implementing IROFS FA6-003

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 activities performed under work request (WR) 301600 regarding replacement of valves

• reviewed Problem Identification, Resolution, and Correction System (PIRCS) entries related to the Area 600 and PSL furnaces from the past 12 months

• reviewed ISA audits for calendar year 2022 in the areas of risk, chemical safety, fire safety, and radiological safety

• reviewed furnace operator qualifications

• observed plan of the day and PIRCS screening meetings

• reviewed fire event 92306

5 88135.02 - Plant Status

The inspectors conducted a series of walk-downs and observations to gain insights into the status of facility activities, risk-inform the selection and implementation of the appropriate core IPs, and ensure compliance with license and regulatory requirements. Specifically, the inspectors routinely conducted walk-downs of licensee areas; observed operators, material control and accounting (MC&A) and security force personnel; inspected postings and licensee guidance documents; interviewed plant personnel; and discussed the results of operational and shift turnover meetings.

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

The inspectors selected the following meetings for review:

• Safety and Security Review Council (SSRC)

• PIRCS Meetings

• Plan of the Day

Record and Log Reviews (IP Section 03.03)

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

The records selected for review are listed in the "Documents Reviewed" section of this inspection report.

Identification and Resolution of Problems (IP Section 03.05)

The inspectors reviewed selected issues 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. The issues selected for review are listed in the "Documents Reviewed" section of this inspection report as PIRCS.

Audits (IP Section 03.07)

The inspectors reviewed the internal and/or external audits listed below to determine whether they were performed in accordance with 10 CFR 70.22(h)(1), if applicable, and the license application.

• Quarterly Safety Audit - ISA/Fire

6

• 2 nd Quarter 2023 Environmental Safety Inspection and Audit

• 2 nd Quarter NCS Audits

• 2 nd Quarter Industrial Safety Report to the SSRC

• MC&A Quarterly Status - 2nd Quarter 2023

Procedures (IP Section 03.08)

The inspectors reviewed selected procedures to determine if the licensee was using and maintaining them in accordance with applicable license requirements. The procedures selected for review are listed in the "Documents Reviewed" section of this inspection report.

Radiation Work Permit (RWP) (IP Section 03.09)

The inspectors reviewed and observed the RWPs or safety work permits (SWPs) listed below to determine whether they contained the information required by Chapter 4, "Radiation Safety," of the license application; the Radiation Protection Manual; and licensee implementing procedures:

• SWP 23-21-018 302-800 associated with work request 297822

• SWP 18521 333 HEU

Annual Security and Emergency Preparedness Drills/Exercises (IP Section 03.10)

The inspectors observed the licensees performance during the Emergency Preparedness training evolution listed below to determine they were being implemented in accordance with 10 CFR 70.22(I)(3):

• emergency training drill conducted on August 24, 2023

88135.04 - Resident Inspection Program Operational Safety

The inspectors reviewed the material condition and as-found configuration of selected site structures, systems, and components (SSCs); reviewed corresponding documentation, and interviewed licensee personnel to verify compliance with 10 CFR Part 70 and the license application. The inspectors also verified whether the selected SSCs were available and reliable to adequately protect plant workers and the public during normal, off-normal, and accident conditions.

Operations Safety Walkdown (IP Section 03.01)

The inspectors performed walk-downs and evaluated the safety controls/IROFS listed below associated with the Area 900 processing area.

• Building 302:

o FA 9-12 o FA 9-35 o FA 9-44

• Building 303:

o FA 9-24 o FA 9-43

7 o FA 9-45

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

The inspectors evaluated the operational status and material condition of selected fire protection 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) standard 801, Standard for Fire Protection for Facilities Handling Radioactive Materials, as applicable. Also, the inspectors evaluated fire brigade training and performance to verify compliance with the fire protection program as described in Chapter 7, Fire Safety of the license application, and NFPA 600, "Standard on Industrial Fire Brigades."

Fire Area Walkdown (IP Section 03.01)

The inspectors walked down and reviewed the documents listed below for two fire areas of the facility:

• Building 304 o Fire Hazard Analysis, Building 304 o Emergency Light Inspection, Building 304 o 150 LB Fire Extinguisher Inspection o Building 304 Pull Station Inspections o Building 304 Fire Door Inspections o Building 304 Fire Wall Inspections o Observation of CO2 Suppression System Testing for Building 302

• Area 900 o IROFS FIRE 9-1 o IROFS FIRE 9-2 o IROFS FIRE 9-3

Fire Brigade Drill Performance Sample (IP Section 03.02)

The inspectors evaluated the fire brigade training and performance during the licensee's response to a false fire alarm as described below:

• The inspectors reviewed lesson plans and completed training records for brigade members for the 1st quarter training conducted at the South Carolina Fire Academy.

• The inspectors observed brigade response, dress out, command and control during response to an accidental pull station activation on July 10, 2023.

88135.17 - Permanent Plant Modifications

The inspectors evaluated the implementation of the configuration management system (CMS) for facility changes or modifications to ensure that safety-related systems, structures, and components (i.e., IROFS or other credited safety controls) could adequately perform their intended safety function and that changes did not adversely impact the operability and safety of the facility.

8 Facility Change/Modifications (IP Section 03.01)

The inspectors reviewed changes/additions to transfer lines associated with tanks in the 302 and 304 buildings to determine whether these were implemented in accordance with 10 CFR 70.72, Facility changes and change process. Specifically, the inspectors reviewed the following:

• change control package ECR 2020915

• work order (WO) 304360

• SWP 18218

• setpoint verification memo

• Letter of Authorization 2375D-004, "Guidance for newly installed transfer line"

• NFS-HS-CL-10-00, Revision (Rev.) 49, "Nuclear Criticality Safety Buildings 302/303/304/306/307 Miscellaneous Stations"

88135.19 - Post-Maintenance Testing

The inspectors evaluated post-maintenance test activities to verify compliance with Chapter 11, Management Measures, of the license application; and test procedures and/or WOs to confirm functional capability of selected IROFS and/or safety control(s) following maintenance.

Post-Maintenance Testing (IP Section 03.01)

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

• N302PSHLPNZN101, WR 310479

• N303XIGNTBSS672, conducted on July 8, 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 verify compliance with Chapter 11, Management Measures, of the license application, and the requirements of 10 CFR 70.61 and 70.62; and to verify the IROFS maintained their operational readiness consistent with the ISA Summary.

Surveillance and Calibration Testing (IP Section 03.01)

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

• N302FURDOOR 600 Area

• N302XXXXLSHNIA1

• N302XXXXLSHNIA2

• N302XXXXLSHNIA3

• N302XXCO2SYSTEM

9 RADIOLOGICAL CONTROLS

88030 - Radiation Protection

The inspectors evaluated selected aspects of the licensees radiation protection (RP) and radiological waste (RW) programs to verify compliance with selected portions of 10 CFR 19, 20, 61, and 70; Chapter 4, Radiation Protection, of the facilitys license application; and applicable licensee procedures.

Radiation Protection Program Implementation (IP Section 02.01)

The inspectors interviewed licensee staff and reviewed licensee procedures and other documentation related to the implementation of the RP and RW programs to verify compliance with 10 CFR 20.1101(a), 10 CFR 61.55-56, and applicable sections of the license application (Section 4.1). Specifically, the inspectors:

• reviewed procedure NFS-GH-908, "Radiation Protection Program," Rev. 8.0

• reviewed the latest assessment of the RP program (2022 As Low as Reasonably Achievable (ALARA) Report)

• interviewed the senior health physicist and RP manager regarding the implementation of the RP program

• reviewed the resume versus the job qualification requirements for the newest member of the RP group

• interviewed the RW program manager regarding waste classification and characterization and off-site waste receipt repositories

Radiation Protection Program Review (IP Section 02.02)

The inspectors reviewed the licensees ALARA reports and audit/self-assessment records to verify compliance with 10 CFR 20.1101(c), 20.2102, and applicable sections of the license application (Section 4.2 and Section 11.5). Specifically, the inspectors:

• reviewed ALARA goals for calendar years 2021 and 2022 and the revised 2021 ALARA goals for projects ALARA unit

• reviewed the 2 nd and 3rd Quarter 2021 ALARA Performance Reports for Occupational Exposure

• reviewed 4 th Quarter 2022 ALARA Occupational Performance Report

• reviewed assessments of the RP program and RW program (see the "Documents Reviewed" section of this inspection report)

• reviewed audits performed by RP personnel in various areas of the site (see the "Documents Reviewed" section of this inspection report)

• reviewed audits performed by RW personnel on outgoing shipments and temporary, on-site storage areas (see the "Documents Reviewed" section of this inspection report)

10 Radiation Protection and Radioactive Waste Procedures (IP Section 02.03)

The inspectors assessed the licensees review and implementation of RP and RW procedures to verify compliance with 10 CFR Parts 20 and 61 and applicable sections of the license application (Section 11.4). Specifically, the inspectors:

• reviewed RP and RW procedures (see the list in the "Documents Reviewed" section of this inspection report)

Training (IP Section 02.04)

The inspectors interviewed licensee staff and reviewed training records and training procedures related to RP and RW to verify compliance with 10 CFR 19.12, 19.13, and applicable sections of the license application (Sections 4.5 and 11.3). Specifically, the inspectors:

• reviewed the following training procedures:

o NFS-GH-39, "Radiological Safety Training," Rev. 11 o NFS-HS-A-12, "Radiation Technician Training Procedure," Rev. 3 o NFS-GH-919, "Radiological Safety Training Program"

• interviewed licensee Radiation Technicians (RTs) on first and second shifts and various RTs located in the RT main office, production areas 600/700, Building 440 operations, and the wastewater treatment facility

• interviewed new production technicians in areas 600/700 about their recent radiological training and applied knowledge regarding the equipment they operate

• reviewed radiological safety training programs

• reviewed samples of training records associated with a cross section of RTs to verify currency in training requirements as defined in NFS-HS-A-12

Safety-Significant Events (IP Section 02.05)

The inspectors reviewed RP-related and RW-related corrective action program entries to verify compliance with 10 CFR 20.2202, 20.2203, 70.50, 70.74, 70 Appendix A, and applicable sections of the license application (Section 11.6). Specifically, the inspectors reviewed the following documents associated with RP program challenges in the area of training, compliance, and supervision:

• PIRCS 85125 - Relocation of work area boundary under SWP 21-09-016 and WO 298198

• PIRCS 86967 and associated tap root investigation I303306, flow-down PIRCS 88847,88484, 88849, 88850; and Radiation Protection Audit for SWP Program, 2nd Quarter 2022

• PIRCS 87903 - Donning and doffing of contamination control protective clothing

• PIRCS 88233 - Construction workers awareness of potentially contaminated construction wastes, debris, and personal protective equipment (PPE); and compliance with GH-03/SOP-335-A

• PIRCS 88574 - Corrective actions on replacing deficient radiological signage identified in routine Safety Audit, per NFS-HS-B-49

11

• PIRCS 88972 - Work area contamination report dated 7/31/2022 (SWP 18270 dated 7/28/2022)

• PIRCS 89191 - Laboratory 105 equipment (WOs 305420, 305421, 305422, 305423)

• Health and Safety Contamination Report, Building 302, investigation dated 10/01/2021

Radiation Work Permits (IP Section 02.06)

The inspectors interviewed licensee staff and reviewed samples of SWPs to verify compliance with the license application (Section 4.4.6). Specifically, the inspectors:

• reviewed and observed work in progress under SWP #18497 - Replace Pump, 303-BLDG, Area B

• reviewed the SWP for work in progress inside Building 234

• reviewed procedure NFS-GH-03, "Safety Work Permits," Rev. 23

Instrument Calibration (IP Section 02.07)

The inspectors interviewed licensee staff and reviewed licensee procedures/records for RP instrument calibration to verify compliance with 10 CFR 20.1501(c) and 70.24 and applicable sections of the license application (Section 4.7.12). Specifically, the inspectors:

• observed alpha, beta, and gamma detectors and Tennelec counters were within calibration

• observed response checks for select alpha, beta, and gamma detectors and verified calibration dates

• observed the calibration and alarm response of a whole-body contamination detector

• observed the daily response checks for alpha and beta friskers and a whole-body contamination detector

• reviewed the calibration record for IROFS 333 - UDOWNB (in-line monitor)

• reviewed procedure NFS-HS-A-05, "Calibrating Radiation Monitoring Instruments," Rev. 22

Instruments and Equipment (IP Section 02.08)

The inspectors interviewed licensee staff and reviewed the licensees use of radiation and contamination detecting instruments and equipment to verify compliance with 10 CFR 20.1501(a) and applicable sections of the license application (Section 4.7.12). Specifically, the inspectors:

• observed response checks on a personnel contamination monitor, alpha frisker, and beta frisker

• observed whole body contamination detectors in use

• observed alpha, beta, and gamma detectors in use

• reviewed documentation of a Hi-Volume sampling activity in Building 302 to support an SWP down posting to verify compliance with HFS-HS-B-32

• walked down IROFS (in-line monitors) in the hot zone to verify functionality and equipment condition

12 Posting (IP Section 02.09)

This inspection procedure section was completed during routine inspection activities conducted throughout the year by the NRC senior resident inspector under IP 88135.

Container Labeling (IP Section 02.10)

This inspection procedure section was completed during routine inspection activities conducted throughout the year by the NRC senior resident inspector under IP 88135.

Posting of Notices (IP Section 02.11)

This inspection procedure section was completed during routine inspection activities conducted throughout the year by the NRC senior resident inspector under IP 88135.

Access Control (IP Section 02.12)

The inspectors observed the licensees access control measures to radiation areas to verify compliance with sections of the license application (Sections 4.4.2 and 4.4.4). Specifically, the inspectors:

• observed badge-in and badge-out stations for access to/from material access areas (MAAs)

• observed that access to MAAs was also controlled by security guards

• reviewed procedure NFS-GH-42, "Establishing and Posting Radiologically Controlled Areas," Rev. 7

Licensed Material Control (IP Section 02.13)

The inspectors observed the licensees measures to secure stored material and control and maintain constant surveillance of licensed material not in storage to verify compliance with 10 CFR 20.1801 and 20.1802. Specifically, the inspectors:

• observed a storage vault to verify that licensed material was secured from unauthorized removal or access

• observed a sample of radiological material outside of vaults was stored with measures to prevent unauthorized removal or access

• observed that radiological material outside of vaults was stored in geometrically favorable containers

Radiation Surveys (IP Section 02.14)

The inspectors observed a survey and reviewed records of the licensees external radiation surveys to verify compliance with 10 CFR 20.1501(a) and applicable sections of the license application (Section 4.7.1). Specifically, the inspectors:

• observed a radiological survey performed on outgoing shipment of RW

• reviewed records of radiological surveys (see the "Documents Reviewed" section of this report)

• reviewed procedure NFS-HS-B-03, "Routine Dose Rate Surveys," Rev. 13

13 Contamination Control (IP Section 02.15)

The inspectors observed and reviewed records of the licensees contamination control measures to verify compliance with 10 CFR 20.1501(a) and applicable sections of the license application (Section 4.7.11). Specifically, the inspectors:

• reviewed records of contamination surveys conducted over the last six months

• observed a contamination survey performed on an outgoing shipment of RW containers

• walked down the facility for counting contamination filters

• observed the digital process for performing contamination surveys within radiologically controlled areas

• reviewed procedure NFS-HS-B-80, "Contamination Surveys," Rev. 14

• reviewed procedure NFS-GH-01, "Contamination Control," Rev. 37

Sealed Sources (IP Section 02.16)

The inspectors observed the licensees storage and control of NRC-licensed sealed sources and reviewed records to verify compliance with 10 CFR 20.1903(c) and applicable sections of the license application (Section 4.8.3). Specifically, the inspectors:

• reviewed the latest record for NRC-licensed sealed sources and observed that none were at an activity level that required leak testing

• reviewed procedure NFS-HS-B-46, "Performing Sealed Source Leak Checks,"

Rev. 12

• observed storage of sealed sources

• observed usage of sealed sources for response checks and calibrations of survey instruments and contamination monitors

Occupational Dose Results (IP Section 02.17)

The inspectors reviewed records of the occupational doses assigned to workers to verify compliance with 10 CFR 20.1201 and 20.1208 and applicable sections of the license application (Section 4.7). Specifically, the inspectors:

• reviewed internal, external, and total dose records for employees who had received the highest doses

• evaluated exposure data for all employees during the previous 18 months to confirm compliance with regulatory requirements

• reviewed dose records for declared pregnant workers to confirm compliance with regulatory requirements

• discussed the new employee radiological exposure computer software implemented in 2023. The review included in-depth discussions of software documentation, discussions about differences between the previous and new software, and review of functional verification and validation activities to ensure data accuracy

14 Exposure Controls (IP Section 02.18)

The inspectors interviewed licensee staff and observed engineering controls used keep doses ALARA by controlling the amount of airborne radioactive material to verify compliance with 10 CFR 20.1101(b), 20.1701, 20.1702, and applicable sections of the license application (Sections 4.6 and 4.7). Specifically, the inspectors:

• observed usage of gloveboxes, fume/vapor hoods, and open face enclosures

• observed the airflow direction being from areas of less contamination to areas of higher contamination (i.e., negative pressure)

• observed access to the radiologically controlled areas via badge reader

• observed stationery air filter change-outs and reviewed results from previous change-outs

• walked down the respirator supply and cleaning building and examined select respirators for damage

• walked down the facility to determine whether respirators of varying sizes were available at designated locations

• reviewed process enclosure face-air-velocity reports (FM-HS-B-44-01, Rev.

5); measurement/testing records of air capture velocity at gloveboxes and ventilation hoods, including 105 Lab, B-Lab, D-Lab East, D-Lab West, gloveboxes in 301/302/303/304/306/307/333; and select building doors, conducted during August 2023

Bioassay Program (IP Section 02.19)

The inspectors interviewed licensee staff and reviewed the internal bioassay program to verify compliance with 10 CFR 20.2103(b)(3) and applicable sections of the license application (Section 4.7.5). Specifically, the inspectors:

• interviewed licensee staff regarding on-site processing of internal bioassay and air sampling

• reviewed procedures NFS-GH-08, "Collection of Bioassay Samples," Rev. 11 and NFS-HS-A-29, "Plant Action Limits and Investigation for Bioassay Measurements," Rev. 12

• reviewed internal bioassay records

• reviewed air sampling survey records

• walked down the on-site internal bioassay laboratory

Whole Body Counting (IP Section 02.20)

The inspectors interviewed licensee staff and observed the lung counting facility and reviewed lung counting records to verify compliance with the applicable sections of the license application (Section 4.7). Specifically, the inspectors:

• walked down the lung counting facility

• interviewed licensee personnel regarding the implementation of the lung counter

• reviewed document 21T-22-0009, Health Physics Audit for External Dosimetry Program, 4th Quarter 2021

15 Dosimetry (IP Section 02.21)

The inspectors interviewed licensee staff, observed dosimetry being used, and reviewed dosimetry records to verify compliance with 10 CFR 20.1501(d), 20.1502(a) and applicable sections of the license application (Section 4.7.6). Specifically, the inspectors:

• reviewed the National Voluntary Laboratory Accreditation Program (NVLAP) accreditation for the licensee's dosimeter processor

• reviewed procedures NFS-HS-B-09, "Dosimeter Use and Exchange," Rev. 18 and NFS-GH-16, "External Dosimetry Program," Rev. 20

• observed licensee employees wearing dosimetry during normal work activities

Dose Assessment Programmatic Review (IP Section 02.22)

The inspectors interviewed licensee staff and reviewed records and calculations related to the licensees assessment of the dose to workers to verify compliance with 10 CFR 20.1202, 20.1204, 20.1502(b), and 20.2106 and applicable sections of the license application (Sections 4.7 and 4.8). Specifically, the inspectors:

• reviewed the procedure for committed effective dose equivalent (CEDE) and total effective dose equivalent (TEDE) calculations

• reviewed quarterly and yearly records of the internal, external, and total dose results

• reviewed validations (hand-written calculations) used to verify software-generated dose calculations

• interviewed the senior health physicist regarding the accuracy of the dose calculations and any exceedance of in-house action levels

As Low As Reasonably Achievable (IP Section 02.23)

The inspectors interviewed licensee staff and reviewed records related to the implementation of the ALARA program to verify compliance with 10 CFR 20.1101(b) and applicable sections of the license application (Section 4.2). Specifically, the inspectors:

• reviewed the 2022 ALARA report

• reviewed safety review committee minutes from 2022 through 2023

• interviewed the RP manager regarding the ALARA program

FACILITY SUPPORT

88051 - Evaluation of Exercises and Drills

The inspectors observed and evaluated the licensees graded biennial exercise conducted on September 28, 2023, as well as briefings and critiques involving both on-site participants to verify compliance with 10 CFR 70.22(i)(3)(xii) and the Nuclear Fuel Services Emergency Plan, Rev. 28. The scenario involved a vehicle accident, potentially contaminated personnel injuries, and a post-crash fire impacting the material access area potentially affecting radioactive material.

16 Exercise Planning (IP Section 02.01)

The inspectors reviewed the emergency exercise scenario, discussed the exercise objectives with licensee personnel, observed controller meetings, and walked down the plant areas before the exercise to verify compliance with the Emergency Plan, Emergency Plan Implementing Procedures, and 10 CFR 70.22(i)(3)(xii). The inspectors reviewed or observed the following:

• the frequency of exercises conducted by the licensee

• the scenario as it related to testing all elements of the Emergency Plan

• pre-staging of equipment in preparation for the exercise

• duties and responsibilities for exercise personnel including controllers, evaluators, and observers

• the controllers' meeting for the emergency exercise

• the objectives of the exercise and the expectations from responders

• the post-drill critique for the emergency exercise

Exercise Execution and Emergency Plan Implementation (IP Section 02.02)

The inspectors observed the initiation of the emergency exercise, the activation of the Emergency Operations Center (EOC) and Plant Emergency Organization, classification of the event, notification of off-site response organizations, establishment of the incident command post, implementation of field response teams, and reviewed on-site and off-site communications, releases and notifications to verify compliance with the Emergency Plan, Emergency Plan Implementing Procedures, and 10 CFR 70.22(i)(3)(xii). The inspectors observed and reviewed the following:

• the licensees analysis of plant conditions including assessment and classification of the accident scenario within the allowable time limits

• staffing for all EOC/emergency organization positions

• drafting of off-site notifications including a review of content and time of issuance

• on-site communication to occupational workers as it related to protective action recommendations

• occupational workers participation in protective actions and the process to conduct personnel accountability

• press release approval and issuance

• Emergency Director control of the EOC/emergency organization and drill

• dose assessor use of dose software

• response coordinators recommendations regarding conditions for terminating the event and restarting normal operations

• recovery and re-entry recommendations implemented by the EOC/emergency organization

• members of the licensees emergency response team assembly at designated assembly areas and the arrival of off-site emergency responders to include the Erwin Fire department and local ambulance providers

• response to emerging situations to address the exercise scenario and meet the exercise objectives

• the Incident Commander's control of the emergency response team and coordination of actions with off-site emergency responders

17 Critiques, Exercise Control, and Identification and Resolution of Problems (IP Section 02.03)

The inspectors observed the staff critiques of the emergency exercise and reviewed the licensees related corrective action program entries to verify compliance with the Emergency Plan, Emergency Plan Implementing Procedures, and 10 CFR 70.22(i)(3)(xii). The inspectors reviewed and observed the following:

OTHER AREAS

92709 - Licensee Strike Contingency Plans

The United Steel Workers (USW) Union represents hundreds of workers at the NFS facility. The contract between the USW Union and NFS was scheduled to expire at midnight on May 15, 2023. On April 19, 2023, negotiations between the USW Union and the licensee resulted in a contract extension until October 15, 2023. On September 24, 2023, a five-year contract proposal was ratified by union personnel as a result of additional negotiations.

Prior to the accepted contract proposal, the NRC staff continued inspection activities in accordance with NRC IP 92709, Licensee Strike Contingency Plans. The inspectors reviewed updates to the licensees strike contingency plan and discussed the implementation of the plan with licensee management, operations, and security personnel to evaluate the plans adequacy and to assess the licensees readiness in the event of contract expiration and a possible labor strike.

The inspectors continued a review of the licensees preparations to ensure that the required minimum number of qualified personnel would be available for the proper and safe operation of the facility. The inspectors also focused on the licensees plans to provide adequate site security in the event of a labor-related work stoppage. Specifically, the inspectors continued review of the licensees assumptions in developing associated contingencies, training, and staffing plans including:

• the number and job classifications of potential strikers;

• the readiness of the safety contingency plan;

• the process for training and qualifying sufficient salaried staff for safety-critical positions;

• how critical safety and regulatory functions would transition to salaried personnel during a potential strike; and

• how the potential labor strike could affect the current contract between the licensee and the guard union to ensure hourly guard force continued performing their assigned duties in the event of a work stoppage.

Additionally, the inspectors again contacted representatives of the Erwin City Police Department to discuss the NRCs ongoing oversight role in the event of any potential labor dispute and the need to ensure continued unfettered site access to the licensees facility should a work stoppage ensue. The inspectors also discussed with the USW Local President and Vice President the NRCs oversight role in the event of a job action and the federal regulations granting NRC staff unfettered access to and from the site.

18 INSPECTION RESULTS

No issues were identified.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

• On July 20, 2023, the inspectors presented the operational safety (IP 88020) inspection results to Ronald Dailey and other members of the licensee staff.

• On September 21, 2023, the inspectors presented the radiation protection (IP 88030) inspection results to Ronald Dailey and other members of the licensee staff.

• On September 28, 2023, the inspectors presented the Emergency Preparedness Exercise (IP 88051) inspection results to Ronald Dailey and other members of the licensee staff.

• On October 16, 2023, the inspectors presented the resident core inspection (IP 88135) inspection results to Ronald Dailey and other members of the licensee staff.

19 DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or Procedure Date 88020 Calibration Calibration Data Sheets for 302-600 Oxygen Monitors, N/A Records Pressure Gauges, PLC, Thermocouples, Thermometers, Temperature Controllers, and Scales from July 2022 to July 2023

FM-QM-044 Calibration of 302 Area 600 Special Gas Detectors Serial# Rev. 1 302/693 and 302/669 from performed from June 2022 through June 2023 Corrective Action PIRC 45321 Review of NCSE Risk Indexing Documents PIRCS # 92236 Safety-Related Equipment; Equipment Functioning but 04/11/2023 Challenged/Degraded Problem Report Problem ID 91570 - Rule not Followed 1/29/2023 Problem Report Problem ID 91657 - Safety-Related Equipment; Equipment 02/08/2023 failed to operate as designed Problem Report Problem ID 91776 - Integrated Safety Analysis; IROFS 02/01/2023 Function Failure/Degradation problem Report Problem ID 91200 - Integrated Safety Analysis 03/29/2023 Problem Report Problem ID 92306-Fire/Explosion/Over Pressurization; No 04/18/2023 Property Damaged Problem Report Problem ID92724 - Spill/Leak/Release; Indoors; Liquid; 06/07/2023 Radiological; Outside Containment Problem Report Problem ID 92235 - Safety-Related Equipment; Equipment 04/11/2023 function Challenged/Degraded Drawings 303-F0910 PSL 600 Interlock Narrative 10/26/2018 303-F0914 PSL 600 Interlock Narrative, 2 of 5 Engineering Fire Risk Evaluation 05A: Building 302 Area 600 Evaluations 21X-21-0017 ISA Safety Basis Risk Assessment Support & Justification, Rev. 2 302 600/303 PSL 600 21X-23-0006 IROFS 303-PSL600700A Rev. 11 Engineering, Combustible Gas Detection System Functional Design 1/27/2022 internal Specification specification

20 Inspection Type Designation Description or Title Revision or Procedure Date NCSE 54X Area 600 Rev. 3 0024 Miscellaneous Operation for Unloading Area 600 302 Furnace Post Event Rev. 0 92306 Job Qualifications for Manufacturing Ops Section Manager 07/19/2023 and Plant Superintendent Manager List of Job Requirements for 302-600-700A and 303-PSL- 07/19/2023 600-700A Operators A5E00109528-07 Simatic Industrial Software Safety Eng in SIMAIC S7 07/2013 FDS-NFS-303-Operating Guidance/Manual, PLC, PSL Rev. 4 131505 LOA-2375D-035-Addition of Mettler Toledo ICS465k-35LA Scales in Fuel 04/21/2023 01 Manufacturing Facility LOA-ENG Authorization for Temporary Deviation from SOP 409, 05/11/2023 014-07 Section 62, and NFS-HS-CL-04, Table 1 LOA-HS-22-006 Authorization to Deviate from NFS-HS-E-02 to Perform 02/28/2023 Speaker Audibility Testing Procedures NFS-CAP-009 The NFS Corrective Action Program Rev. 10 NFS-DOC-002-03 Letter of Authorization Rev. 2 NFS-GH-36-01 Lockout/Tagout - Physical Work Rev. 9 NFS-GH-43 Safety-Related Equipment Control Program 04/19/2022 NFS-HS-A-068 ISA Risk Assessment Procedure Rev. 10 NFS-M-17 Calibration System Manual Rev. 34 NFS-OPS-001 Conduct of Operations Rev. 20 NFS-WM-008 Calibration of Electronics Equipment by Electronics Rev. 1 Maintenance Safety-Related IROFS Procedure 302303-600700A and 300-UPVENT July 2022 -

Equipment (SRE) July 2023 Test SOP 401-06 FMF Building 302 Area 600 Rev. 2a SOP 401-06A Area 600 PSL Rev. 5a 303 SOP 401-07C-Area 700 Sublot Prep Rev. 5 303

21 Inspection Type Designation Description or Title Revision or Procedure Date SOP-416 Programmable Logic Controller Configuration Control Rev. 8 Program Self-Assessments 21T-22-1280 2nd Quarter 2022 Audit Checklist for the 100 NDA 07/12/2022 HEA-21 Laboratory Radiological ACE Revision 1 MSU-22-032 21T-22-1448 1st Quarter 2022 ISA Chemical ACE Audit for the 09/02/2022 HEA-21 Occupational/Environmental Chemical Accident LDT-22-009 Consequence Evaluation 300 Complex and Building 100 Fires, Revision 11 21T-22-1463 3rd Quarter 2022 Chemical IROFS Audit for Fuel 09/12/2022 HEA-21 Production, Recovery, and Supporting Areas KG-22-001 21T-22-1500 3rd Quarter 2022 ISA Risk Assessment Audit Checklist for 09/26/2022 HEA-21 Fuel Support Areas (RA-300-FUEL SUPPORT AREAS)

EAS-22-063 21T-22-1790 4th Quarter 2022 ISA Risk Assessment Audit Checklist for 11/28/2022 HEA-21 Bldg 333 (RA-333-UGENER)

EAS-22-066 21T-23-0271 1st Quarter 2023 ISA Risk Assessment Audit for Bldg. 304 02/10/2023 HEA-21 Area LA (RA-304-AREA LA)

EAS-23-009 21T-23-0313 1st Quarter 2023 ISA Audit for Fire Radiological ACE, 02/28/2023 HEA-21 Revision 3.1(prototype markup)

MSU-23-002 21T-23-0338 1st Quarter 2023 ISA Risk assessment Audit Checklist for 03/03/2023 HEA-21 Fuel Area 800 (RA FUEL AREA 800)

EAS-23-015 21T-23-0383 2nd Quarter 2023 ISA Audit for Document FHA-FRE B110, 04/17/2023 HEA-21 Revision 1 EAS-23-023 21T-23-0387 1st Quarter 2023 ISA Chemical ACE Audit Checklist for the 03/30/2023 HEA-21 Occupational/Environmental Chemical Accident KMK-23-015 Consequence Evaluation, BLEU Prep Facility Rev.

[P00013.1]

22 Inspection Type Designation Description or Title Revision or Procedure Date 21T-23-0427 2nd Quarter 2023 ISA Chemical ACE Audit Checklist for the 04/14/2023 HEA-21 Occupational/Environmental Chemical Accident KMK-23-016 Consequence Evaluation, Waste Discard Tanks. Revision 8 21T-23-1778 4th Quarter 2022 ISA Audit Checklist for the Production Fuel 11/21/2022 HEA-21 Facility Radiological ACE, Revision 5 MSU-22-038 Work Orders Work Request Replace the Ball Screw Actuator Assemblies for the Elevator 5/15/2023 (WR) #301637 302-FRNCOV-0601 WR 301600 Replace 302-FV-0656 and 302-FV-0657 07/20/2023 88030 Calibration IROFS 333 - UDOWNB (In-Line Monitor) 09/19/2023 Records Corrective Action 93849 Pu-239 source used to check beta meter. Pu-239 is no a 09/20/2023 Documents beta emitter.

Resulting from 93852 ARGOS contamination monitor - calibration procedure (NFS- 09/20/2023 Inspection HS-A-121) had ambiguity, errors, and inconsistences for alpha and beta settings. Location-110B Miscellaneous Monthly Check - IROFS 300-General (In-Line Monitor for 09/05/2023 Waste Water)

Monthly Check - IROFS 333-ULDISC (In-Line Monitor for 09/13/2023 Condensate)

Monthly Check - IROFS 333 - USVXTR (In-Line Monitor for 09/13/2023 Raffinate)

Ludlum Measurements, Inc. - Model 44 Hand Held March 2022 Pancake Probe - Alpha, Beta, Gamma Radiation Detector NVLAP Accreditation - Mirion Technologies (GDS), Inc.,

2017 RP & Nuclear Measurements Organizational Chart Safety and Safeguards Review Council (SSRC), Meeting Minutes - March 4, 2021; September 2, 2021; December 2, 2021; March 3, 2022; April 7, 2022; June 2, 2022; October 6, 2022; December 8, 2022; March 9, 2023 Resume of new employee into the RP group 4th Quarter 2022 ALARA Occupational Performance Report ALARA Goals for January 1, 2022, through December 31, 03/02/2022

23 Inspection Type Designation Description or Title Revision or Procedure Date 2022 4th Quarter 2021 ALARA Occupational Performance Report ALARA Goals for January 1, 2021, through December 31, 01/17/2021 2021 Revised 2021 ALARA Goals for Projects ALARA Unit 09/03/2021 2nd Quarter 2021 ALARA Performance Report for 09/02/2021 Occupational Exposure 3rd Quarter 2021 ALARA Performance Report for 12/02/2021 Occupational Exposure 183381 Contamination Survey - Intensive - related to 183380 2023 183955 Contamination Survey - Pre-Job Survey - Enclosure 2023 184006 Contamination Survey - Investigative - 306-800 2023 184008 Contamination Survey - Investigative - 307-800 2023 184602 Contamination Survey - SWP - SWP 23-06-003 2023 Procedures FM-HS-A-05-02 Criticality Alarm Testing Form Rev. 3 NFS-GH-01 Contamination Control Rev. 37 NFS-GH-03 Safety Work Permits Rev. 23 NFS-GH-07 Respiratory Protection Program Rev. 25 NFS-GH-08 Collection of Bioassay Samples Rev. 11 NFS-GH-16 External Dosimetry Program Rev. 20 NFS-GH-38 Identification and Handling of Potential Hazardous Waste Rev. 9 NFS-GH-39 Radiological Safety Training Rev. 11 NFS-GH-42 Establishing and Posting Radiologically Controlled Areas Rev. 7 NFS-GH-908 Radiation Protection Program Rev. 8 NFS-GH-919 Radiological Safety Training Program Rev. 3 NFS-GH-925 Radiation Monitoring Program Rev. 3 NFS-HS-A-12 Radiation Technician Training Procedure Rev. 13 NFS-HS-A-121 Calibrations of the ARGOS PCM Rev. 0 NFS-HS-A-16 Safety Audits, Assessments, and Inspections Rev. 16 NFS-HS-A-16-01 Health Physics Inspection Checklist Rev. 0 NFS-HS-A-29, Plant Action Limits and Investigation for Bioassay Rev. 12 Plant Action Measurements Limits and

24 Inspection Type Designation Description or Title Revision or Procedure Date Investigation for Bioassay Measurements, Rev. 12 NFS-HS-A-53 Routine Inspections and Surveys Rev. 9 NFS-HS-A-56 QA Program for In Vitro / In Vivo Measurements Rev. 6 NFS-HS-B-03 Routine Dose Rate Surveys Rev. 13 NFS-HS-B-09 Dosimeter Use and Exchange Rev. 8 NFS-HS-B-35 Daily Personnel Monitor Source and Response Verification Rev. 20 NFS-HS-B-35-01 Canberra ARGOS 5AB Whole Body Monitor Rev. 2 NFS-HS-B-39 Radioactive Material Receipt and Shipping Surveys Rev. 31 NFS-HS-B-42 Quality Assurance & Respirator Maintenance Rev. 25 NFS-HS-B-44 Process Enclosure Face-Air-Velocity Measurements (Alnor Rev. 16 Model AVM410)

NFS-HS-B-46 Performing Sealed Source Leak Checks Rev. 12 NFS-HS-B-49 Posting Radiological Areas and Inspecting Radiation Rev. 16 Warning Signs NFS-HS-B-54 Operation of Portable Contamination Monitoring InstrumentsRev. 10 NFS-HS-B-80 Contamination Surveys Rev. 14 NFS-HS-B-99 Radiological Job Coverage Rev. 2 NFS-MGT-15-046 Radiation Safety Policy Rev. 2 NFS-WST-021 NFS Waste Characterization Implementation Plan Rev. 13 SOP 335-P NFS Waste Management Process Manual Rev. 2 Radiation ALARA - Gamma Surveys - Building 302 & 303 09/2023 Surveys ALARA - Contamination Surveys - 300 Complex Exit, 300 Complex Entrance, Step Off Pad (SOP), 300 Complex West, 302, 302 Platform, and 303 FM-HS-B-39-03 Radioactive Waste Shipment Contamination Survey - Waste 09/19/2023 Control Specialists (WCS) Shipments @ 0830 and 1336 FM-HS-B-39-04 Radioactive Waste Shipment Radiation Survey - Waste 09/19/2023 Control Specialists (WCS) Shipment @ 0830 and 1336 FM-HS-B-39-06 Shipping Container Survey Report Rev. 2 FM-HS-B-39-09 LR230 In-Progress Tracking Sheet Rev. 2

25 Inspection Type Designation Description or Title Revision or Procedure Date HEA-02-01-21 H&S Contamination Report 09/20/2023 HEA-02-01-21-04 H&S Contamination Report 09/20/2023 HEA-02-01-22-03 H&S Contamination Report 09/18/2023 HEA-02-04 Shipping Container Survey Form 09/06/2023 HEA-20-01-76-06 H&S Contamination Report 09/19/2023 NFS-HS-B-39-07 Shipping Container Survey Report Rev. 2 Radiation Work SWP # 18497 Replace Pump, 303-BLDG, Area B 09/21/2023 Permits (RWPs)

Self-Assessments DMT-23-001 BPF Operations January 2023 01/31/2023 DMT-23-003 HP Audit for Radiation Technician Training Program, 1st Qtr 2023 JBH-22-004 Radiation Worker Training Audit 2nd Quarter 2022 06/30/2022 JBH-23-001 HP Inspection For Vaults and Storage Areas 12/2022 JKT-22-004 HP Audit of ALARA Program 3rd Qtr of 2022 09/22/2022 JTW-22-005 HP Mth Insp Radiological Postings 05/31/2022 JTW-23-003 HP Audit of the Radiation Protection Program for 2022 02/28/2023 KJR-22-001 HP Audit for External Dosimetry Prog Q4-2021 21T-22-0009 KJR-23-012 Radiation Worker Training Audit 2nd Quarter 2023 06/30/2023 LS-22-001 Radiation Protection Audit for SWP Program, Q2, 2022 07/19/2022 RTR-21-008 Audit Rad Lab Q4-2021 21T-21-0981 RTR-22-007 Safety Audit of Radioanalytical Labs 12/23/2022 88051 Miscellaneous 21G-23-0091 Submittal of Biennial Exercise Objectives and Scenario 07/19/2023 Detail 21G-23-0126 Submittal of Biennial Exercise Objectives and Scenario 09/05/2023 Detail NFS-GH-903 Emergency Plan Rev. 28 Procedures NFS-HS-E-02 Emergency Criticality Evacuation Rev. 50 NFS-HS-E-03 Emergency Response Organization Rev. 38 NFS-HS-E-04 Fire Reporting and Response Rev. 42 NFS-HS-E-08 Off-Site Radiological Emergency Assessment Rev. 33 NFS-HS-E-10 Emergency Communications Rev. 32 NFS-HS-E-11 Radiological Scene and Contamination Control Rev. 25 NFS-HS-E-15 Emergency Medical Response Rev. 21

26 Inspection Type Designation Description or Title Revision or Procedure Date 88135.02 Corrective Action PIRCS 92243 Documents PIRCS 92925 PIRCS 92926 PIRCS 92931 PIRCS 92956 PIRCS 92964 PIRCS 929986 PIRCS 93169 PIRCS 93195 PIRCS 93208 PIRCS 93210 PIRCS 93357 PIRCS 93358 PIRCS 93403 PIRCS 93478 Procedures NFS-OPS-001 Conduct of Operations Rev. 020 NFS-PD-001 Management Of the On-Line Training and Qualification Rev. 008 System SOP 409 Section BPF, Loading and Staging LR-230 Containers Rev. 18.D 45

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