IR 07100938/2024201

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Inspection Report No. 71-00938/2024-201 - Orano Federal Services, LLC
ML24156A068
Person / Time
Site: 07100938
Issue date: 06/05/2024
From: Hector Rodriguez-Luccioni
NRC/NMSS/DFM/IOB
To: Courtney G
Orano Federal Services
References
IR 2024201
Download: ML24156A068 (16)
v • d • e


Text

June 5, 2024

SUBJECT:

U.S. NUCLEAR REGULATORY COMMISSION INSPECTION REPORT NO.

710938/2024201

Dear Gregory Courtney:

On April 23, 2024, through April 25, 2024, the U.S. Nuclear Regulatory Commission (NRC)

conducted an announced onsite team inspection at Orano Federal Services, LLC (OFS) in Federal Way, WA. The team discussed the preliminary results of this inspection with OFS representatives on April 25, 2024. The enclosed report presents the results of this inspection.

The purpose of the inspection was to verify and assess the adequacy of OFSs design, procurement, repair, and any modification and maintenance activities, for which OFS is the holder of the Certificates of Compliance (CoC), associated with the transportation of radioactive material to determine if they were performed in accordance with the requirements of Title 10 of the Code of Federal Regulations (10 CFR) Part 71, Packaging and Transportation of Radioactive Material, selected portions of 10 CFR Part 21, Reporting of Defects and Noncompliance, and your NRC-approved Quality Assurance Program (QAP), approval number 0938, revision 7 (OFS QAP No. MN-ORANO-FS-QPI-00001, dated November 11, 2021).

The inspection scope examined activities conducted under OFSs QAP as they relate to public health and safety, and to confirm compliance with the Commissions rules and regulations and with the conditions of the applicable CoCs. Within these areas, the inspection consisted of selected examination of quality assurance procedures, design records, procurement of spare parts records and interviews with personnel. The enclosed report presents the results of this inspection.

No violations of more than minor significance were identified during this inspection. In accordance with 10 CFR 2.390, Public inspections, exemptions, requests for withholding, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room (PDR) or from the Publicly Available Records component of the NRCs Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html. The PDR is open by appointment. To make an appointment to visit the PDR, please send an email to PDR.Resource@nrc.gov or call 18003974209 or 3014154737 between 8 a.m. and 4 p.m. eastern time (ET), Monday through Friday, except Federal holidays.

No reply to this letter is required. We appreciate your cooperation.

Sincerely, Signed by Rodriguez-Luccioni, Hector on 06/05/24 Hector Rodriguez-Luccioni, Chief Inspection and Oversight Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards

Docket No. 710938

Enclosure:

NRC Inspection Report No.

710938/2024201

ML24156A068 C = COVER E = COVER & ENCLOSURE N = NO COPY

  • via email OFFICE DFM DFM DFM NAME ELove SFigueroa HRodriguez-Luccioni DATE 6/4/2024 6/5/2024 6/5/2024

U.S. NUCLEAR REGULATORY COMMISSION Office of Nuclear Material Safety and Safeguards Division of Fuel Management

Docket:

710938

Report.:

710938/2024201 Enterprise Identifier: I2024201-0029 Certificate Holder:

Orano Federal Services, LLC Location:

Federal Way, WA

Inspection Dates:

April 24, 2024, through April 26, 2024

Inspection Team:

Earl Love, Senior, Transportation and Storage Safety Inspector Team Leader

Marlone Davis, Senior, Transportation and Storage Safety Inspector

Azmi Djapari, Transportation and Storage Safety Inspector

Approved By:

Hector Rodriguez-Luccioni, Branch Chief Inspection and Oversight Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards

Enclosure

U.S. NUCLEAR REGULATORY COMMISSION Office of Nuclear Material Safety and Safeguards Division of Fuel Management

EXECUTIVE SUMMARY

Orano Federal Services LLC

NRC Inspection Report 710938/2024201

On April 26, 2024, through April 28, 2024, the U.S. Nuclear Regulatory Commission (NRC)conducted an announced onsite team inspection at Orano Federal Services LLC (OFS), Federal Way, WA. The purpose of the inspection was to verify and assess the adequacy of OFSs design, procurement, repair, and any modification and maintenance activities, for which OFS is the holder of the CoCs, associated with the transportation of radioactive material to determine if they were performed in accordance with the requirements of Title 10 of the Code of Federal Regulations (10 CFR) Part 71, Packaging and Transportation of Radioactive Material, selected portions of 10 CFR Part 21, Reporting of Defects and Noncompliance, and your NRC-approved QA program (QAP), approval number 0938, revision 7 (OFS QAP No. MN-ORANO-FS-QPI-00001, dated November 11, 2021).

Based on the results of this inspection, the NRC inspection team assessed that overall, the implementation of OFS quality assurance program (QAP) met NRC requirements. The result of the inspection is summarized below and in this enclosed report.

Quality Assurance Program

The team determined that OFS conducted quality related activities on the transportation packagings for which OFS is the holder of the Certificates of Compliance (CoC), as well as their Quality Assurance Program Description (QAMPD), and had effective quality procedures in place in various disciplines (e.g, administration, quality, configuration, engineering, project management, purchasing, etc.) (Section 1.1)

10 CFR Part 21

The team determined that OFS had provisions in place for reporting defects which could cause a substantial safety hazard, as required by 10 CFR Part 21. The team noted that OFSs personnel were familiar with the reporting requirements of 10 CFR Part 21, and the OFS personnel complied with 10 CFR 21.6, "Posting requirements." (Section 1.2)

Design Control

The team determined that CoCs for which OFS is the CoC holder, all the current design control related procedures contained adequate steps, detail, and the required independent reviews to ensure proper quality and to adequately implement the design control portion of the OFS QA program consistent with the design commitments and requirements documented in the applicable safety analysis reports (SARs) and transportation packaging CoCs. (Section 1.3)

Maintenance Control

The team determined that maintenance instructions and specifications were comprehensive and met acceptance criteria for tests identified in the packaging SARs and CoCs. (Section 1.4)

Procurement Control

The team determined that procurement activities conform to the design commitments and requirements contained in the SAR and CoC. (Section 1.5)

Non-Conformance and Corrective Action

The team concluded that OFS effectively implemented its nonconformance control and corrective action program and had adequate procedures in place to ensure compliance with the applicable regulations and QA program requirements. (Sections 1.6 and 1.7)

Audit Program

The team concluded that OFS had an adequate audit program in place to schedule, evaluate, and document the results. The team determined that OFS appropriately identified issues and documented them in the corrective action program as required. (Section 1.8)

REPORT DETAILS

1.0 Design, Fabrication, Testing, and Maintenance of Transportation Packagings (Inspection Procedure (IP) 86001)1.1 Quality Assurance Program 1.1.1 Inspection Scope The team assessed how Orano Federal Services LLC (OFS) performed work under its NRC-approved Quality Assurance Program Description (QAPD), MN-ORANO-FS-QPI-00001, dated November 11, 2021, as well as various procedures to assess the effectiveness of their QAPD implementation. The team conducted reviews of OFS procedures to determine whether OFS adequately controlled and implemented activities under their NRC-approved QAP and activities subject to Title 10 of the Code of Federal Regulations (10 CFR) Part 71 regulations. The team reviewed procedures to verify if OFS clearly defined and documented the quality program authorities and responsibilities and that the quality assurance organization functioned as an independent group. The team also reviewed procedures for the use of a graded approach for identifying important-to-safety (ITS) components. The team reviewed procedures and documents regarding training, qualification, and certification of personnel involved in quality activities. The team reviewed the following:

  • QAPD, Section 1.0, Organization
  • QAPD, Section 2.0, Quality Assurance Program
  • PR-ORANO-FS-QPI-00003, Management and Independent Assessment, Revision 0
  • PR-ORANO-FS-QPI-00016, Corrective Action, Recommendations and Lessons Learned, Revision 1,
  • PR-ORANO-FS-TNG-00001, Training and Qualification, Revision 2 1.1.2 Observations and Findings The team assessed that OFSs QAP and implementing procedures were effective in conducting quality activities. The team verified that the quality program authorities and responsibilities were clearly defined and documented, and the quality assurance organization functioned as an independent group. In addition, the team verified that OFSs procedures adequately prescribed a graded approach in the identification of ITS components. The team determined that for the sample of OFS training records reviewed, that all personnel completed the required training. No findings were identified.

Conclusions The team concluded that OFS had adequate quality assurance controls and independence related to other activities. The team also determined that OFS conducts its training of personnel and uses a graded approach for ITS components in accordance with their NRC approved QAPD.

1.2 10 CFR Part 21 1.2.1 Inspection Scope The team reviewed the 10 CFR Part 21 standard procedure PR-ORANO-FS-QPI-00015, Revision 1, Reportability Determinations to verify whether provisions were in place for reporting defects that could cause a substantial safety hazard and to complete the required notification in a timely manner. The team interviewed personnel to verify if they were familiar with the implementing procedure. The team also verified that OFS complied with 10 CFR 21.6, Posting requirements.

1.2.2 Observation and Findings The team assessed that OFS has provisions in place for evaluating deviations and reporting defects that could cause a substantial safety hazard, as required by 10 CFR Part 21. The team noted that the 10 CFR Part 21 posting at OFSs facility met the applicable requirements of 10 CFR Part 21. No findings were identified.

1.2.3 Conclusions The team determined that provisions are in place for reporting defects which could cause a substantial safety hazard, that personnel were familiar with the reporting requirements of 10 CFR Part 21; and that OFS complied with 10 CFR 21.6.

1.3 Design Controls 1.3.1 Inspection Scope The team interviewed selected personnel and reviewed selected design documentation to determine that adequate design controls are implemented. The team focused its review in the areas of design modifications, quality classification evaluation for structures, systems, and components, and OFSs procurement of ANSYS, Inc. software programs.

1.3.2 Observations and Findings With respect to OFS procurement of software programs, the team noted ANSYS, software is used for finite element analysis model for design and operation activities to determine the stresses for the comparison to the American Society of Mechanical Engineers code stress limit for Transportation Packagings.

The team noted OFS contracted with ANSYS, Inc. for the procurement of software based on a quality assurance service agreement (QASA) that met a quality system consistent with Appendix B to 10 CFR Part 50. The team reviewed ANSYS, Inc.s QASA and noted applicable services include customers audit access, error reports, verification testing packages, and technical support. With respect to error reporting, the team noted ANSYS, Inc. as contractually committed to notify users of the software of the Program of the Class3 Errors (e.g., a program error which permits or generated a solution that may appear reasonable and correct, but which in fact may be erroneous) for each user to determine whether the error(s) impacts any safety-related activities or are reportable pursuant to 10 CFR Part 21. To address this issue, OFS initiated a corrective action Report (CAR), CR-2024-0024, applicable to 10 CFR Part 21 reporting. The team noted, corrective actions included software procedural enhancements, placement of additional purchase order terms and conditions, and enhancement of approved supplier list to add restrictions, as applicable to Part 21 reportability. The team determined OFSs CA to be adequate and noted OFSs commitment to continue to engage the Nuclear Industry Assessment Corporation (NIAC) on final resolution with ANSYS, Inc.

The team reviewed OFS design activities related to CoC No. 9393 for the Crystal River 3 Reactor Vessel Shipping Container (CR3RVSC) and noted that fabrication of CR3 Middle Package was performed "at-risk," in part, due to NRCs ongoing review for approval of the package, Docket No. 71-9393. The team noted that OFS does not have a risk release process to provide sufficient definition to adequately assure open issues identified at the point of at-risk purchase order release to the fabricator will be controlled through the fabrication process up to the point that actions have occurred enabling the lift of the "at-risk status. The team noted OFSs recognition that an opportunity exists to improve the licensing process/procedure to prescribe a more prescriptive approach to final reconciliation of the fabrication documents to the final approved licensing/SAR basis prior to NRC approval of a CoC up to the point that actions have occurred enabling the lift of the at-risk status. The team noted OFSs issuance of CAR 2024-027 to address this issue. The team considered this an observation, in part, because OFS performed a fabrication document reconciliation as required by OFS procedure No. PR-ORANO-FS-EN-00015, Revision 001, Radioactive Material Packaging Licensing, in that, OFSs project team lead reconciled the SAR drawings to the fabrication drawings to ensure that SAR drawing requirements were fully implemented in the fabrication documents. The team reviewed the following documents:

  • PR-ORANO-FS-QPI-00008, Certificates of Conformance, Revision 1
  • PR-ORANO-FS-QPI-000158, Reportability Determinations, Revision 1
  • PR-ORANO-FS-EN-00003, Engineering Drawings, Revision 1
  • PR-ORANO-FS-EN-00006, Development of Software, Revision 2
  • PR-ORANO-FS-EN-00011, Use and Management of Engineering Application Software, Revision 0
  • PR-ORANO-FS-EN-00013, Classification of Components for 10CFR71 and 10CFR 72 Applications, Revision 0
  • PR-ORANO-FS-EN-00014, Procurement and Qualification of Procured Engineering Application Software, Revision 0
  • PR-ORANO-FS-EN-00015, Radioactive Material Packaging Licensing, Revision 1
  • PR-ORANO-FS-EN-00017, Engineering Software Error Reporting and Evaluation, Revision 1
  • PR-ORANO-FS-EN-00018, Fabrication and Construction Readiness Review, Revision 0
  • ANSYS, Inc., Quality Services Agreement, dated January 01, 2023 (OFS Account Number 520074)
  • ANSYS, Inc. Certificate of Conformance, dated March 8, 2024, Ansys Structural Mechanics Verification Testing Package, Release 2024 R1 (24.1), Version: Windows
  • PKG-GF-SPC-003, General Fabrication Specification, Revision 7
  • CR3 RV RVI LC, Certificate of Conformance Checklist, dated August 17, 2023
  • CR3 RV RVI LC, Certificate of Conformance, dated August 17, 2023

1.3.3 Conclusions The inspection team determined that all the current design control related procedures, contained adequate steps, detail, and the required independent reviews to ensure proper quality and to adequately implement the design control portion of the OFS QAPD.

1.4 Maintenance 1.4.1 Inspection Scope The team reviewed selected spare part procurement records and interviewed personnel to verify that OFS effectively supports a maintenance control program in accordance with their NRC-approved QAP, CoC conditions, and the requirements of 10 CFR Part 71 for the transportation of radioactive material. The team reviewed maintenance requirements identified in the SARs and CoCs, and discussed personnel qualifications and training with the OFS staff, as applicable. This included a review of the project plans and other related documents related to procurement of spare parts for the TRUPACT-III and other maintenance support since the corporate office does not perform any maintenance activities on-site.

1.4.2 Observations and Findings The team noted that OFS supported limited maintenance activities from the corporate office for the CoCs held for their transportation packages. The team assessed that OFS procured the appropriate spare parts for maintenance activities related to the TRUPACT-III. The team also assessed that OFS personnel developed and provided maintenance instructions and specifications for the maintenance requirements identified in the SARs and CoCs in accordance with their quality assurance manual and procedures.

1.4.3 Conclusion Overall, the team concluded that OFS supports maintenance activities on their CoCs for transportation packagings in accordance with project plans, and other related documents such as the procurement of spare parts to ensure its compliance with the SARs and other standards for maintenance activities.

1.5 Procurement Controls 1.5.1 Inspection Scope The team reviewed processes and procedures that addressed procurement, including receipt inspection, traceability of material, and commercial grade dedication, as applicable. The team reviewed selected drawings and records and interviewed personnel to verify that procurement specification for materials, fabrication, and inspection met design commitments and requirements contained in SARs and CoCs.

The team reviewed quality procedures, receipt inspection records, and sampled purchase orders (POs). The team focused its review on the procurement of items and services associated with the fabrication of the CR3MP transportation packaging. The team reviewed the following documents:

  • PR-ORANO-FS-QPI-00004, "Control of Purchased Materials, Parts & Components, and Services" Revision 0
  • PR-ORANO-FS-EN-00013, "Classification of Components for 10CFR71 and 10CFR72 Applications," Revision 0
  • Purchase Order (PO) 2020-1235 The team also reviewed the OFS supplier audit program to determine if OFS scheduled, planned, and performed supplier audits in accordance with their implementing procedures, referenced standards, and guidance documents (see section 1.8).
  • PR-ORANO-FS-QPI-00005, "Supplier Evaluations," Revision 1

Revision 0

  • PR-ORANO-FS-QPI-00007, Receipt Inspections, Revision 0

1.5.2 Observations and Findings:

Overall, the team assessed that OFS had adequate control of the procurement process for the ITS components selected and reviewed. The team determined that the OFS procured ITS components consistent with design requirements and their QAP implementing procedures. OFS also purchased and applied controls over sub-contractors and vendors currently on the approved suppliers list. The team assessed that OFS had adequate controls over material traceability, procurement, and receipt inspection. Additionally, OFS verified and maintained the traceability throughout the procurement and receipt process. The material ordered and received fabrication of the CR3MP met the design requirements, and the critical characteristics for dedicated material. The team also assessed that the POs were adequate and specified the applicable criteria and requirements including Part 21. No findings were identified.

1.5.3 Conclusion:

The team determined that materials, components, and other equipment received by OFS for fabrication activities met procurement specifications, and the specifications conform to the requirements in the SAR and applicable 10 CFR Part 71 requirements. This included the use of the commercial grade dedication process to procure commercial items and calibration services using NRC endorsed guidance documents.

1.6 Nonconformance Controls 1.6.1 Inspection Scope The team reviewed selected records and interviewed personnel to verify that OFS effectively implemented a nonconformance control program in accordance with the requirements of 10 CFR Part 71 and OFSs nonconformance QA program. The team reviewed nonconformance reports (NCRs) and verified that the NCRs were identifiable, traceable, and that the disposition of the nonconformance was adequate. The team reviewed the following documents:

  • PR-ORANO-FS-QPI-00013, Inspection, Test, and Operating Status, Revision 0
  • PR-ORANO-FS-QPI-00014, Control of Nonconforming Items, Revision 1 The team reviewed a sample of NCRs and supplier nonconformance reports (SNRs) for the CR3-MP package since the last NRC Part 71 inspection in 2019. The review focused on NCRs that were dispositioned as Use-As-Is" and Repair, to determine if OFS had justified their dispositions of the NCRs and SNRs adequately.

1.6.2 Observations and Findings Overall, the team assessed that OFS had adequate nonconformance controls in place to identify, track, and resolve quality related deficiencies and deviations. The nonconformances reviewed were appropriately dispositioned and resolved in a timely manner and in accordance with implementing procedures. No findings of were identified.

1.6.3 Conclusions The team concluded that OFS effectively implemented its nonconformance control program and had adequate procedures in place to ensure compliance with the applicable regulations and QAP requirements.

1.7 Corrective Actions 1.7.1 Inspection Scope The team reviewed selected records and interviewed personnel to verify that OFS effectively implemented a corrective action program (CAP) in accordance with the requirements of 10 CFR Part 71 and OFSs corrective action procedures. The team reviewed a selected sample of corrective action reports (CARs) in order to verify that OFS completed corrective actions for identified deficiencies in a technically sound and timely manner. The team reviewed the following documents:

  • PR-ORANO-FS-QPI-00016, Corrective Action, Recommendations and Lessons Learned, Revision 1 The team reviewed a sample of CARs generated since the last inspection in 2019, including condition reports (CR), 2019-652, and 2019-807 which were initiated as a result of that inspection. The CRs were reviewed to determine whether OFS completed corrective actions for identified deficiencies in a technically sound and timely manner.

The review focused on corrective actions for Significance Level 2, 3, and 4, with Level 4 being the least significant. Since the last inspection, there were no CRs categorized as Significance Level 1, which denotes the most significant condition adverse to quality.

1.7.2 Observations and Findings

Overall, the team assessed that OFS had adequate procedures and controls in place for identifying and writing CARs, documenting corrective action(s) taken, performing causal analyses as necessary, documenting corrective actions and actions taken to prevent recurrence as applicable, performing CAR closure verification, and tracking CARs to closure. The team also determined that the corrective actions initiated as a result of the last inspection were adequate and resolved in a timely manner in accordance with implementing procedures. No findings were identified.

1.7.3 Conclusions The team concluded that OFS effectively implemented its CAP and had adequate procedures in place to ensure compliance with the applicable regulations and QAP requirements.

1.8 Audits 1.8.1 Inspection Scope The team reviewed the internal audit program to verify that OFS scheduled, planned, and conducted audits in accordance with their QAP and implementing procedures. The team reviewed the audit results to determine if OFS identified deficiencies and addressed these deficiencies within their corrective action program this included a review of checklist the audit teams used to document the objective evidence reviewed while performing the internal audits.

The team selected a sample of internal audits and interviewed personnel to verify that OFS effectively implemented their audit program from 2019 to the present. This sample included a review of lead auditor qualifications and annual assessments. In addition, the team reviewed the last four management reviews of the QAP to determine whether OFS management performed the reviews as required and if the reviews were an effective tool to use for the overall health of the quality assurance program.

The team reviewed the following quality implementing procedures:

  • PR-ORANO-FS-QPI-00018, Internal Audits, Revision 0
  • PR-ORANO-FS-QPI-00019, Surveillance, Revision 0
  • PR-ORANO-CORP-QPI-0001, Qualification of Audit Personnel, Revision 0
  • PR-ORANO-FS-QPI-00003, Management and Independent Assessment, Revision 0

1.8.2 Observations and Findings The team confirmed that Holtec performs internal audits on a yearly basis and that OFS audits all eighteen QAP elements. The team noted that OFS develops audit plans and schedule audits in accordance with approved quality procedures. The audit plans identify the organization being audited, audit scope, requirements, audit team members, activities for audit, applicable documents, and audit checklists. The team noted that OFS provided objective evidence, documentation, and examined to the depth necessary all audited areas. The team noted that OFS lead auditors issued and signed all audit reports. The team assessed that OFS scheduled and performed internal audits and internal surveillances in accordance with their implementing procedures.

Additionally, the team noted that the auditors identified issues during the audit and that OFS captured all the issues as either observations or findings. The team noted that OFS closed and provided evidence, which included, when necessary, a root cause analysis and appropriate corrective actions taken to resolve findings in a timely manner. This included a performance verification of adequate implementation of the corrective actions taken on previous internal audits.

As far as external audits, the team noted that OFS may use the NIAC services for external audits. The team determined that the NIAC audit packages used audit plans, reports, and NIAC checklists to provide detailed documentation of suppliers. The team noted that OFS followed its procedures by performing an audit review checklist to accept the audit as its own and assessed them to be very thorough with the use of checklists and documented evidence. The team assessed that the NIAC lead auditor had completed the required training and attained the applicable qualifications to perform duties as a lead auditor. No findings were identified.

1.8.3 Conclusion The team determined that OFS performed internal and external (supplier) audits as scheduled in accordance with QAP requirements for transportation packaging activities and that OFS resolved deficiencies if identified during the audit in a timely manner.

2.0 Entrance and Exit Meeting On April 25, 2023, the NRC inspection team discussed the scope of the inspection during an entrance meeting with members of OFS staff. The team completed the inspection and conducted an inspection exit meeting on April 28, 2024. Section 1 of the attachment to this report shows the attendance for the entrance and exit meetings.

ATTACHMENT

1. ENTRANCE/EXIT MEETING ATTENDEES AND INDIVIDUALS INTERVIEWED

Name Title Affiliation Entrance Exit Earl Love Team Leader, Senior Transportation & Storage Safety Inspector NRC X

X Marlone Davis Senior, Transportation & Storage Safety Inspector NRC X

X Azmi Djapari Safety Inspector NRC X

X Gregory Courtney Senior Manager, Environmental, Safety, Health, and Quality OFS X

X Chris Backus Packaging Licensing Manager OFS X

X Slade Klein Engineering Manager OFS X

X Michael Schuster Quality Specialist OFS X

X

2. INSPECTION PROCEDURES (IP) and GUIDANCE DOCUMENTS USED

IP 86001

Design, Fabrication, Testing, and Maintenance of Transportation

Packagings NUREG/CR6314 Quality Assurance Inspections for Shipping and Storage Containers NUREG/CR6407 Classification of Transportation Packaging and Dry Spent Fuel Storage

System Components According to Importance to Safety

3. LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Item Number Status Type Description 710952/2019201-01 Closed NCV 1) Failure to perform an apparent cause analysis for a corrective action report (CAR 2019-652)2) Failure to document objective evidence and identify findings as unsatisfactory during a supplier audit (CAR 2019-807)

4. LIST OF ACRONYMS USED

ADAMS

Agencywide Documents Access and Management ASL

Approved Suppliers List CAP

Corrective Action Program CAR

Corrective Action Report CFR

Code of Federal Regulations CoC

Certificate of Compliance CR

Condition Report CR3RVSC Crystal River 3 Reactor Vessel Shipping Container IP

Inspection Procedure ITS

Important to Safety ITS-A

Important to Safety - Category A NCR

Nonconformance Report NCV

Non-Cited Violation NIAC

Nuclear Industry Assessment Corporation NRC

Nuclear Regulatory Commission OFS

Orano Federal Services, LLC PO

Purchase Order QA

Quality Assurance QAP

Quality Assurance Program QAPD

Quality Assurance Program Description QASA

Quality Assurance Service Agreement QP

Quality Procedure SAR

Safety Analysis Report

5.

DOCUMENTS REVIEWED

Certificate holder and maintenance documents reviewed during the inspection were

specifically identified in the Report Details above.

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