ML24190A073

Urenco USA – Integrated Inspection Report 07003103/2024002

ML24190A073
Person / Time
Site:	07003103
Issue date:	07/09/2024
From:	Timothy Sippel NRC/RGN-II/DFFI
To:	Lorskulsint P Louisiana Energy Services, URENCO USA
References
EN57061 IR 2024002
Download: ML24190A073 (21)

Text

EN57061 Paul Lorskulsint Chief Nuclear Officer Louisiana Energy Services (LES) dba Urenco USA (UUSA)

Urenco USA P.O. Box 1789 Eunice, NM 88231

SUBJECT:

URENCO USA - INTEGRATED INSPECTION REPORT 07003103/2024002

Dear Paul Lorskulsint:

On June 27, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed inspections at URENCO USA and discussed the results of this inspection with you and other members of your staff. 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, Robert E. Williams, Jr., Chief Projects Branch 1 Division of Fuel Facility Inspection Docket No. 07003103 License No. SNM-2010

Enclosure:

As stated cc w/ encl: Distribution via LISTSERVJuly 9, 2024 Signed by Williams, Robert on 07/09/24

ML24190A073 X Non-Sensitive X Publicly Available X SUNSI Review Sensitive Non-Publicly Available

OFFICE RII/DFFI RII/DFFI RII/DFFI RII/DFFI RII/DFFI RII/DFFI NAME C. Oelstrom J. Raudabaugh T. Shewmaker N. Peterka T. Sippel R. Williams DATE 7/8/24 7/8/24 7/8/24 7/9/24 7/8/24 7/9/24 U.S. NUCLEAR REGULATORY COMMISSION Inspection Report

Docket Number: 07003103

License Number: SNM-2010

Report Number: 07003103/2024002

Licensee: Louisiana Energy Services (LES) dba Urenco USA (UUSA)

Facility: URENCO USA

Location: Eunice, NM

Inspection Dates: April 1 to June 30, 2024

Inspectors: C. Oelstrom, Fuel Facilities Inspector N. Peterka, Sr. Fuel Facility Project Inspector J. Raudabaugh, Fuel Facility Inspector T. Shewmaker, Fuel Facility Inspector

Approved By: Robert E. Williams, Jr., 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 an integrated inspection at URENCO USA, 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 WER 07003103/2024-002-00 RETRACTED: Item Relied 88075 Closed On For Safety Inoperable (EN57061)

2 PLANT STATUS

The UUSA Facility in Eunice, New Mexico enriches uranium hexafluoride (UF6) using gas centrifuge technology. During the inspection period, normal production activities were ongoing.

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

IP 88015 - Nuclear Criticality Safety

The inspectors evaluated selected aspects of the licensees nuclear criticality safety (NCS) program to verify compliance with selected portions of Title 10 of the Code of Federal Regulations (10 CFR) 70, "Domestic Licensing of Special Nuclear Material," including 70.24, 70.50, 70.61, 70.62, Part 70 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 criticality safety analyses (CSAs),

and associated documentation and calculations, to verify compliance with 10 CFR 70 and applicable sections of the license application, including portions of 5.1.2, 5.2.1.2, 5.2.1.3, 5.2.1.4, and 5.2.1.6. Specifically, the inspectors interviewed licensee staff and reviewed the following CSAs and supporting documents:

• NCS-CSA-037, "Nuclear Criticality Safety Analysis of Slab Tanks," Revision (Rev.) 0, including the review of what-if analysis, double contingency principle, normal, credible abnormal, and non-credible accident sequences

• NCS-CSA-022, "Safe Spacing for SBD Drums Involving Decontamination,"

Rev. 4, including the review of the engineering evaluation for implementing item relied on for safety (IROFS) 58a/b

• NCS-CSA-013, "Nuclear Criticality Safety Analysis of 55-Gallon Waste Drums," Rev. 7, including review the review of what-if analysis, double contingency principle, normal, credible abnormal accident sequences

• NCS-CSA-016, "Criticality Safety Analysis of 30B Cylinders," Rev. 8, including the review of double contingency principle and normal accident sequences

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, and plant walkdowns to verify compliance with 10 CFR 70 and applicable sections of the license application, including portions of sections 5.1.1 and 5.1.2. Specifically, the inspectors interviewed licensee staff and reviewed the following IROFS associated with the Product Take-Off System and the Liquid Effluent Collection and Transfer System (LECTS):

• administrative controls on mass, moderation, and spacing (e.g., IROFS 58a/b) including a review of NCS Postings

• engineered control on moderation supporting IROFS 16a, including review of maintenance test records

• procedures (e.g., RW-3-2000-01, "LECTS Operations") that implement NCS administrative IROFS 55a/b for mass control and sampling

• the inspectors conducted walkdowns in the LECTS room to verify that floor storage arrays and equipment was as described in the NCSEs

• the inspectors conducted walkdowns in Separation Building Modules (SBM) 1001, 1003, and the LECTS room

• the inspectors observed NCS postings in the field to verify they were posted as required and contained IROFS information

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, including portions of sections 5.1.1, 5.1.5, and 11.3.3.1.1. Specifically, the inspectors performed the following activities:

• observed a licensee NCS engineer conduct a weekly NCS inspection in the SBM 1001/1003/1005 Mass Spec Rooms and reviewed recent weekly NCS walkdowns

• interviewed licensee NCS engineers and management concerning schedule, conduct, results, and documentation of the weekly NCS inspections and the NCS quarterly audits

• interviewed LECTS operators regarding LECTS tank sampling and transfers for IROFS 55a/b

• reviewed 2023 Nuclear Safety Worker Training

4 Criticality Programmatic Oversight (IP Section 02.04)

The inspectors reviewed NCS program procedures, audits, and NCS staff qualifications records to verify compliance with 10 CFR 70 and applicable sections of the license application, including 5.1.1, 5.1.5, and 11.5. Specifically, the inspectors interviewed licensee NCS staff and reviewed the following documents:

• reviewed current version of NCS Program Procedures, including CR-2-1000-01 and CR-3-1000-04

• reviewed qualification status for two NCS Engineers, and interviewed two NCS Engineers about NCS training and qualification

• interviewed NCS staff concerning the NCS review of changes, including changes to operating procedures that may affect NCS, and changes to the facility

• reviewed samples of liquids taken in the LECTS room slab tanks prior to transfer to unfavorable geometry storage tanks

Criticality Incident Response and Corrective Action (IP Section 02.05)

The inspectors reviewed the licensees corrective action program (CAP) to verify compliance with 10 CFR 70. Specifically, the inspectors observed activities, reviewed documents, and/or interviewed licensee staff concerning the following:

• NCS-related CAP entries listed in the "Documents Reviewed" section of this report

• interviewed licensee staff about upcoming changes and the future expansion project to the Criticality Accident Alarm System

IP 88055 - Fire Protection

The inspectors evaluated selected aspects of the licensees fire protection program to determine whether the operational status, material condition and design of fire protection systems met the applicable requirements of 10 CFR 70, Chapter 7, "Fire Safety" of the facilitys SAR, and applicable licensee procedures.

5 Selection of Inspection Samples (IP Section 02.01)

The inspectors reviewed licensing documents to select a sample of fire protection features in risk-significant areas/processes, including IROFS and their respective management measures (where applicable). The inspectors also selected licensee activities that support the implementation of the fire protection program based on the program description included in the SAR. Specifically, the inspectors performed the following:

• observed weekly IROFS36a and IROFS36d transient combustible material loading walkdown by operations personnel

• observed maintenance testing on VESDA detection system in the Cylinder Receipt and Dispatch Building (CRDB)

• walked down a sample of IROFS35

• reviewed management measures for selected administrative, passive, and active engineered IROFS

• interviewed fire protection engineer, training staff, operators, and managers regarding configuration management change of the structural fire brigade to an incipient fire brigade

• reviewed training and qualifications of fire brigade personnel and fire protection engineer

• reviewed compensatory measures for fire-related impairments

• reviewed Memorandums of Understanding (MOUs) with offsite agencies

• audits and self-assessments of the fore protection program

Preventative Controls (IP Section 02.02)

The inspectors interviewed licensee staff, reviewed documentation, and conducted plant walkdowns to verify the licensees controls for combustibles and ignition sources met the license requirements and applicable requirements in 10 CFR 70. Specifically, the inspectors conducted the inspection activities listed below:

• interviewed licensee operators and engineers, reviewed records of walkdowns, and conducted plant walkdowns in the CRDB, SBM-1001, SBM-1003, UBC Storage Pad, and other areas to verify controls for transient and fixed combustible material were being implemented in accordance with IROFS and procedural requirements

• observed weekly IROFS36a and IROFS36d combustible material loading walkdowns

• conducted plant walkdowns, interviewed operators, engineers and maintenance personnel, and reviewed records to verify ignition sources were controlled in accordance with procedural requirements

• interviewed licensee staff and management, performed system walkdowns, reviewed procedures and completed maintenance records to verify IROFS35 was being maintained as required to ensure they remained available and reliable to perform their safety function

• reviewed a sample of hot work permits

• reviewed fire watch logs related to impairments maintenance

6 Fire and Gas Detection and Alarm Systems (IP Section 02.03)

The inspectors reviewed selected fire or gas detection devices to verify that detection and alarm systems were able to detect the minimal fire within the required time and initiate the safety function credited in the SAR. Specifically, the inspectors conducted the inspection activities listed below:

• observed annual VESDA Inspection, Zone Data, and Functional Test in the CRDB

• interviewed licensee maintenance personnel and reviewed records related to the VESDA system

• conducted plant walkdowns in the CRDB to verify fire detection and alarm systems were installed and maintained as required

Suppression Systems and Activities (IP Section 02.04)

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

• interviewed licensee engineers and maintenance personnel, reviewed the licensee's pre-fire plan, and conducted walkdowns in the CRDB, SBM-1001, SBM-1003, and UBC Pad to verify the licensee maintains firefighting equipment (e.g., fire extinguishers) in designated locations

• interviewed licensee engineers and operators, reviewed procedures and pre-fire plan, walked down various areas of the plant to verify fire suppression activities do not damage safety controls

• walked down fire suppression equipment (e.g., portable fire extinguishers) to verify compliance with the pre-fire plan

Passive Fire Protection Features (IP Section 02.05)

The inspectors reviewed selected passive fire protection features to verify these were in a proper material condition to perform the safety function credited in the SAR or the ISA Summary. Specifically, the inspectors performed the following activities:

• interviewed licensee operators, engineers and maintenance personnel; reviewed impairments, procedures, and work orders; and conducted walkdowns to verify IROFS35 met the license and ISA requirements

• reviewed maintenance records relating to inspection and testing of IROFS35 fire doors and fire damper

7 Fire Protection Program Elements (IP Section 02.06)

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

• interviewed licensee engineers and reviewed training material and impairment records to verify that compensatory measures (e.g., a fire watch) were imposed when IROFS were impaired

• reviewed records and conducted interviews to verify that site fire brigade training and drills were conducted in accordance with license requirements

• interviewed licensee fire protection staff to verify the staffing level, training, and experience of the fire protection organization met license requirements

• reviewed the pre-fire plan, and conducted walkdowns in the CRDB and SBM-1001 to verify the pre-fire plans were consistent with the license requirements and that the pre-fire plan matched conditions in the field

• reviewed the MOUs with the city of Eunice and city of Hobbs fire departments to verify that they were renewed periodically

• reviewed city of Eunice, city of Hobbs, and Lea County Office of Emergency Management

• acknowledgement letters accepting the fire brigade changes

Identification and Resolution of Problems (IP Section 02.07)

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

• EV148297, EV148736, EV149341, EV156313, EV158976, EV161093, EV161255, EV161634, EV162455, EV164419, EV164420, and EV165189

• fire protection audit 2024-A-02-004, and associated EVs and ACs

• the 2021 fire protection self-assessment (SA-2021-007)

FACILITY SUPPORT

IP 88050 - Emergency Preparedness

The inspectors evaluated selected aspects of the licensees emergency preparedness (EP) program to determine whether the program is maintained as required by the Emergency Plan, the license and license application, and NRC requirements in 10 CFR Part 70.

8 Emergency Preparedness Program Review and Implementation (IP Section 02.01)

The inspectors selected the following elements that support the implementation of the licensees EP program to verify compliance with 10 CFR 70.32(i), Chapter 8 of the license application, and the Emergency Plan. Specifically, the inspectors conducted the following inspection activities:

• reviewed changes to the EP Program, including annual updates to the Emergency Plan

• reviewed revisions to the emergency plan implementing procedures that were updated since the last NRC inspection

• conducted plant walkdowns of the Emergency Operations Center (EOC),

Control Room, alternate EOC and the Joint Information Center (JIC)

• reviewed training for the Emergency Response Organization (ERO), including ERO Overview, ERO Classification, ERO Communicator, EOC Operations, and ERO Field Monitor

• reviewed training offered to offsite agencies

• verified required qualifications for two Emergency Directors, a Health Safety &

Environmental Coordinator, and a JIC Manager/JIC Spokesperson

• conducted interviews with the EP Manager regarding program changes, event notifications requiring activation of the ERO, MOUs, communicating changes to the EP Program and ERO Qualifications

• reviewed all active MOUs with offsite agencies

• conducted interviews with Hobbs Fire Chief, Eunice Police Chief, Eunice Fire Chief and representative from the Covenant Health Hobbs Hospital. Many of these Offsite agencies were interviewed last EP inspection, however, every person interviewed was new to their job within a year

• conducted walkdowns of assembly areas and egress routes

• reviewed records of EP drills performed since the last inspection

• reviewed records documenting quarterly communication checks and emergency equipment inventories

Identification and Resolution of Problems (IP Section 02.02)

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

• reviewed corrective actions (EVs) as documented in the documents reviewed section of this inspection report

• reviewed Emergency Preparedness NQA-1 Annual Audit, dated August 30, 2022

• reviewed Emergency Management NQA-1 Audit, dated August 31, 2023

• reviewed 70.32(i) reviews as listed in the document section

• reviewed a list of modifications implemented since the last EP inspection

9 Event Review (IP Section 02.03)

The inspectors reviewed the licensees safety-significant and internal events related to EP to verify compliance with 10 CFR 70.32(i), Chapter 8 of the license application, and the Emergency Plan. Specifically, the inspectors performed the following activities:

• reviewed documents regarding the three seismic events requiring ERO activation since the last inspection o seismic events dated November 16, 2022; December 16, 2022; and November 8, 2023 o reviewed event critiques o notification forms o reviewed EP-related CAP entries o reviewed event notifications

OTHER AREAS

IP 88075 - Event Follow up

On April 1, 2024, at 2345, during the tip up process of the 1003 Liquid Sampling Autoclave to draw a sample of a 30B cylinder, a flexible conduit attached to the autoclave contacted locked closed valve 1003-471-1A12 (a 1/4 turn ball valve), causing the valve to leave its closed seat.

The valve was immediately closed (within 30 seconds) by the operator. The valve is part of the IROFS10 boundary which maintains the leak tight integrity of the autoclave. IROFS10 is the sole IROFS for accidence sequence PB4-3. Because of this, the licensee initially reported the event to the NRC as EN57061, for a one-hour report under 10 CFR 70 Appendix A Section (a)(4)(i).

The inspectors performed a walkdown of the autoclave and reviewed procedures applicable to the event, and other items listed below. There were steps in the procedure that verified no leakage inside the 1003 autoclave including an IROFS10 leak check prior to the evolution and a visual leak check prior to tipping the autoclave. When the conduit made contact with the pressure gage isolation valve, the operator said he had the valve closed within 5 seconds. The autoclave was positioned back to horizontal (normal position) and placed in cooling mode along with the 1001 autoclave which is a similar autoclave. The licensee inspected around both autoclaves to ensure there were no other issues with possible interference with the autoclaves during tipping and none were found. The valve handwheels have been removed and the position of the flexible conduit was moved to prevent the recurrence of the event. The valve handwheels are only needed to operate the valves during surveillance testing performed approximately one time per year.

The licensee did not find any indications of leakage from the 30B cylinder being sampled, so even with that valve being open, there was no potential for UF6 leakage from inside the autoclave. Furthermore, valve 1003-471-1A12 is a pressure gage isolation valve, therefore even with the valve open there would be another (non-IROFS) isolation to the gas barring no failure of the pipe or pressure gage. Prior to the event, valve 1003-471-1A12 had been locked closed with a plastic locking device (like a lock out/tagout locking device), and it was verified locked closed prior to the sampling evolution.

The inspectors noted that there was a similar event in 2019 involving the same valve on a different autoclave being left open. That event was tracked as WER 07003103/2019-005-01,

10 "Open Autoclave Valve (EN 54324)." The licensee's evaluation of that event concluded that the potential consequences were low.

Event Followup

The inspectors reviewed the follow documentation, and interviewed the operator that performed the sampling evolution and licensee engineers:

• operating procedures for implementing IROFS10 at the 1003 autoclave

• drawings of the 1003 autoclave (i.e., ETC4088786-6)

• narrative log entry that documented the performance of IROFS10 verification

• ORM and Boundary Documents for IROFS10

INSPECTION RESULTS

WER RETRACTED: Item Relied On For Safety Inoperable 88075 (EN57061)

WER 2024-002

Description:

On April 18, 2024, the licensee retracted the event after having completed their evaluation of the potential consequences. The retraction stated, "The potential leakage through the open boundary has been determined. The valve, if fully open, would not result in exceeding the 70.61 performance requirements. Thus, the 10 CFR 70(a)(4) reporting requirement was not met, and this event notification is retracted."

In addition to the review of the event described above, the inspectors reviewed the calculations of worst case UF6 release that provide the technical basis for the retraction documented in EV 164778 - AC 180321.

No violations of NRC requirements were identified. Therefore, based on this review WER 70003103/2024-002-00, "RETRACTED: Item Relied On For Safety Inoperable (EN57061)" is closed.

EXIT MEETINGS AND DEBRIEFS

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

• On April 11, 2024, the inspectors presented the nuclear criticality safety and emergency preparedness inspection results to Paul Lorskulsint and other members of the licensee staff.

• On June 27, 2024, the inspectors presented the fire protection inspection results to John Kirkpatrick and other members of the licensee staff.

11 DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or Procedure Date 88015 Corrective Action EV163210, 163514, NCS-Related CAP Entries Various Documents 164442, 164697 Engineering NCS-CSA-013 Nuclear Criticality Safety Analysis of 55-Gallon Waste Rev. 7 Evaluations Drums NCS-CSA-016 Criticality Safety Analysis of 30B Cylinders Rev. 8 NCS-CSA-022 Safe Spacing for SBD Drums Involving Decontamination Rev. 4 NCS-CSA-037 Nuclear Criticality Safety Analysis of the Slab Tanks Rev. 0 NCS-CSE-025 General Storage of Fissile Material Rev. 11 NSR-2023-008 WS251 Pump 30001161450 Nuclear Safety Release Rev. 0 Miscellaneous GXNSWLP00I00ILT Nuclear Safety Worker Training Rev. 13 Purchase Order Safe by Design Attribute Verification Form for SBDV-Completed

1. 1000632801 2023-0037 12/13/2023 Purchase Order Safe by Design Verification Form for SBDV-2024-0003 Completed

1. 4500159096 01/17/2024 Procedures CR-2-1000-01 Nuclear Criticality Safety Program Description Rev. 12 CR-3-1000-03 NCS Weekly Walkthrough and Periodic Assessments Rev. 17 CR-3-1000-04 Response to Nuclear Criticality Safety Anomalous Rev. 6 Condition or Criticality Accident ISA ISA Summary Rev. 34c NEF-BD-16a Administratively Limit Moderator Mass in a New or Rev. 15 Cleaned 30B Cylinder NEF-BD-55a Limit Liquid Effluent Collection and Transfer System Rev. 5 (LECTS) Tank and Tote Uranium Enrichment Inventory NEF-BD-55b Limit Liquid Effluent Collection and Transfer System Rev. 5 (LECTS) Tank and Tote Uranium Enrichment Inventory NEF-BD-58a Maintain Subcritical Mass in a Criticality Safety Rev. 6 Approved Waste Container Storage Array NEF-BD-58b Maintain Subcritical Mass in a Criticality Safety Rev. 6 Approved Waste Container Storage Array RW-3-2000-01 LECTS Operations Rev. 18 SAR Safety Analysis Report Rev. 50d Self-NCSI-23-0036 Mass Spec Rooms (SBMS 1001/1003/1005) 09/05/2023

12 Inspection Type Designation Description or Title Revision or Procedure Date Assessments NCSI-24-0007 Decontamination Workshop 02/16/2024 NCSI-24-0009 USM CAAS 03/01/2024 NCSI-24-0011 SBM 1005 Cascade Halls 03/15/2024 Work Orders WO #1000585898 Monthly: NDA Operations Completed 06/06/2023 WO #1000613451 LECTS SLAB/BST OPS IROFS 55a/b Completed 09/28/2023 WO #1000632001 LECTS SLAB/BST OPS IROFS 55a/b Completed 12/11/2023 WO #1000651094 IROFS C16 RTD CTF Feed/Takeoff Vessel 1V1 Completed 03/20/2024 WO #1000651095 IROFS C16 RTD CTF Feed/Takeoff Vessel 2V1 Completed 03/14/2024 88050 Corrective Action EV151014, 156353, EP-related CAP Entries Various Documents 156452, 156930, 160837, 162478, 162479, 162480, 162481, 162483, EV158573, 158897, Alert Declarations for Seismic Event Reports Various 162743 Miscellaneous ERO Qualification Records for two Emergency 04/10/2024 Directors, a Health Safety & Environmental Coordinator and a JIC Manager/Spokesperson 2024 ERO Roster 03/27/2024 Memorandum of Understanding between UUSA and Lea 08/22/2019 Regional Medical Center Memorandum of Understanding between UUSA and 08/23/2019 New Mexico Department of Public Safety Memorandum of Understanding between UUSA and 09/03/2019 Permian Regional Medical Center Memorandum of Understanding between UUSA and 12/06/2019 New Mexico Department of Homeland Security and Emergency Management Memorandum of Understanding between UUSA and 12/09/2019

13 Inspection Type Designation Description or Title Revision or Procedure Date City of Eunice Police Department, Fire and Rescue Services Memorandum of Understanding between UUSA and 05/27/2020 City of Hobbs Fire Department Memorandum of Understanding between UUSA and Lea 06/23/2021 County Sheriff's Office Emergency Preparedness Organizational Chart 03/25/2024 19-SEP-232R Memorandum of Understanding between UUSA and Lea 09/19/2019 County New Mexico 369EP120 70.32(i) evaluation for adding guidelines for a scenario 10/12/2022 development team into EP-3-0300-03, Drills and Exercises 372EP120 70.32(i) evaluation for Items removed from equipment 04/27/2023 inventory list for EP-3-0300-04, Emergency Preparedness Inventory and Equipment Operability 379EP120 70.32(i) evaluation for Items removed from equipment 04/26/2023 inventory list for EP-3-0300-04, Emergency Preparedness Inventory and Equipment Operability EG-3-4100-04-F-2 T-Installation of HF Monitor for Pilot Testing 08/17/2023 Mod #23-0013 EP Drill Report Fire Impinging on a Container 11/07/2022 EP Drill Report 2023 Criticality Evacuation Drill 01/19/2024 EP Drill Report Operations Practice Drill for NRC Graded Exercise 10/12/2023 EP-3-0200-02-F-2 Emergency Notification Form for Seismic Event 11/16/2022 (Including Everbridge time stamp)

EP-3-0200-02-F-2 Emergency Notification Form for Seismic Event on 11/08/2023 11/08/2023 (Including Everbridge time stamp)

EP-3-0200-02-F-2 Emergency Notification for Seismic Event on 12/16/2022 12/16/2022 (Including Everbridge time stamp)

ERO Overview Emergency Program Overview and class rosters for 02/02/2023 2/2/2023 and 2/20/2023 classes EROClassificationILT Initial ERO Classification Training and class roster dated 05/20/2022 11/9/2023 EROCommunicator ERO Communicator Training 05/20/2020

14 Inspection Type Designation Description or Title Revision or Procedure Date EROEOCOPSILT EOC Operations Training including Rosters for Classes 02/02/2023 dated 1/26/23, 2/2/2023, 2/9/2023 EROFieldMonitoringILT ERO Field Monitoring Training and Rosters from 5/20/2020 Classes dated 1/26/2023, 1/31/2023, 2/9/2023, 2/2/2023 EV151761, 156338, Various critique reports for Drills and exercises Various 158305, 160116, 162667, 162668 LBDCR-20-012 Removal of Meteorological Tower and E-Plan 06/01/2020 Procedures Emergency Plan Rev. 27, 28 and 29 EP-3-0200-02 Emergency Notification Rev. 29 EP-3-0200-06 Assembly and Personnel Accountability Rev. 14 and 15 EP-3-0200-10 Criticality Emergency Response Rev. 10 EP-3-0200-11 EOC Operations Rev. 13 and 14 EP-3-0200-13 Emergency Public Information Plan Rev. 2 and 3 EP-3-0300-01 Maintaining Emergency Preparedness Rev. 19 and 20 EP-3-0300-01 Maintaining Emergency Preparedness Rev. 19 and 20 EP-3-0300-02 Responder Training Rev. 18 and 19 EP-3-0300-03 Drills and Exercises Rev. 10 and 11 EP-3-0300-04 Emergency Preparedness Inventory and Equipment Rev. 31 and Operability 32 EP-4-0200-01 Emergency Action Plan Rev. 0 FP-3-1000-05 Pre-Incident Plan Development and Control Rev. 11 TQ-5-0100-01 Training Requirements Manual, ATT 13 Rev. 9 Self-2022-A-07-015 Emergency Preparedness NQA-1 Annual Audit 08/30/2022 Assessments 2023-A-07-008 Emergency Management NQA-1 Audit 08/31/2023 Work Orders WO 1000575626, Emergency Planning Inventory of Equipment 02/23/2023, 1000590670, 06/19/2023,

15 Inspection Type Designation Description or Title Revision or Procedure Date 1000599646, 09/28/2023, 1000614764 12/12/2023 WO1000590671, Quarterly Site and Offsite Communication Tests 02/23/2023, 1000575627, 06/15/2023, 1000599647, 9/28/2023, 1000614765 12/08/2023 88055 Calculation CALC-F-00001 Fire Hazard Analysis Combustible Loading Rev. 20 FPE-REV-001 Fire Hazard Analysis Rev 21 Corrective Action EV148297, EV148736, Fire Protection Related Corrective Action Items Documents EV149341, EV156313, EV158976, EV161093, EV161255, EV161634, EV162455, EV164419, EV164420, EV165189, and AC 174253, AC180277 Corrective Action EV165928 Records Control and Retention 06/27/2024 Documents Resulting from Inspection Drawings LES-1100-F-FA-002-Fire Alarm System CRDB Ground Floor Section A 06/16/20 01-0 LES-1100-F-FA-006-Fire Alarm System CRDB Second Floor Plan Section A 02/06/2024 01-1 LES-1100-F-FA-028-Fire Alarm System CRDB Faas-1110 Isometric 04/04/2024 01-0 Engineering MOD-21-0009 Revise FPE-REV-001 to Remove TFF6-1 and TFF6-2 03/25/2021 Changes (AC 157195)

Engineering MOD-23-008A CRDB Auxiliary Rollup Door for CRDB Rollup Door 11/08/2023 Evaluations 1100-826-#DO120 Fire Plans FP-3-1000-05 Pre-Incident Plan Development and Control Rev. 11 Miscellaneous Fire Protection Engineer Qualifications, Resume, and Certifications Fire Protection and Emergency Response MOUs with

16 Inspection Type Designation Description or Title Revision or Procedure Date City of Eunice, City of Hobbs, and Lea County Offsite Agency Emergency and Fire Training Material Fire Extinguisher Use Practical - Various Operators 1100-17-2023-044 Transient Combustible Permit 11/10/2023 1100-17-2024-013 Transient Combustibles Permit 04/17/2024 2024-HWP-028, 2024-Various Hot Work Permits HWP-030, 2024-HWP-038, 2024-HWP-056, 2024-HWP-058, 2024-HWP-059 2025-A-02-004 Fire Protection NQA-1 Audit Report 2024 03/15/2024 CC-OP-2017-0007 Reduction of UUSA Fire Brigade Scope Rev. 3 FP-3-1000-09-F-1 Crew A Fire Drill Report 04/01/2024 GCP-060 Updating Fire Brigade Requirements 05/05/2022 Hot Work Fire Watch 06/12/2024 CBT Qualified List I-2022-012, I-2023-Various Impairment Reporting Records 012, I-2023-013, I-2024-001, I-2024-007, I-2024-009 Operability MA-4-0591-01-F-4 1100 Fire Detection Devices Rev. 1 Evaluations Procedures FP-3-1000-01 Fire System and Features Testing and Inspection Rev. 7 FP-3-1000-02 Flammable and Combustible Materials Control Rev. 15 FP-3-1000-03 Fire Prevention During Welding, Cutting, and Other Hot Rev. 14 Work FP-3-1000-04 Fire System or Feature Impairments Rev. 22 FP-3-1000-09 Plant Fire Brigade & Training Rev. 7 FP-3-2000-02 IROFS36e Combustibles Control Inspection - UBC Pad Rev. 5 FP-3-2000-03 IROFS35 Fire Door and Spatial Separation Inspection Rev. 14 and IROFS 36a/36d Combustibles Control Inspection FP-3-2000-04 Fire Door and Spatial Inspection and Combustible Rev. 19 Control Inspection - SBM MA-3-2670-01 Fire Damper Inspections Rev. 10

17 Inspection Type Designation Description or Title Revision or Procedure Date MA-3-2826-01 Fire Barrier Penetration Seals Inspection Rev. 14 MA-3-2826-02 Fire Door Inspections Rev. 17 MA-3-2826-03 Columns Fireproofing Material Inspection Rev. 0 MA-6-0591-01 Annual Fire Detection Tasks Rev. 6 MA-6-0591-02 Semi-Annual Fire Detection Tasks Rev. 5 MA-6-0591-03 Quarterly Fire Detection Tasks Rev. 5 MA-6-0694-02 Quarterly Fire System Inspections and Tests Rev. 5 MA-6-0694-17 Fire Protection Flow Testing Rev. 10 Self-2022-A-03-006 Fire Protection NQA-1 Audit Report 2022 04/11/2022 Assessments 2024-A-02-004 Fire Protection NQA-1 Audit 03/15/2024 SA-2021-007 Fire Protection 2021 Self Assessment Report 11/12/2021 SA-2023-007 Fire Protection 2023 Self Assessment Report 12/12/2023 Work Orders 1000370590 SBM5 Replace Thresholds IROFS35 Doors 11/02/2022 1000448766 4Y: IROFS35 Fire Damper Inspect 03/01/2021 1000561861 1Y: SBM5 IROFS35 Fire Door Inspections 12/12/2022 1000580555 1Y: CRDB IROFS 35 Fire Doors 04/03/2023 1000585777 1Y: IROFS35 Fire Door Inspect 05/16/2023 1000590687 1Y: CRDB Fire Detection Tasks 06/15/2023 1000624747 1DO210 Inadequate Latch 12/04/2023 1000628928 1Y: FWPH Fire System Flow Tests 04/15/2024 88075 Corrective Action EV 164778 - AC Assess 2019 Evaluation for 3LS1 04/17/2024 Documents 180321 EV164778 IROFS10 Boundary Opened During Operation (3LS1) 04/02/2024 Drawings ETC4088786-6 Liquid Sampling Autoclave System 470 P&ID SBM 1003 04/16/2013 Miscellaneous ESOMS Narrative Log IROFS10 ESOMS narrative log entry prior to EN 57061 03/31/2024 LES-1003-E-EQP-001-Separation Building Module Autoclave IROFS10 and 28 02/25/2015 10-1 Boundaries Procedures MA-3-2470-01 Autoclave Leak Check Surveillance IROFS10 Rev. 10 NEF-BD-10 Design Features to Maintain Product Liquid Sampling Rev. 11 Autoclave Leak Tight Integrity OP-3-0470-01 Att. 1 Liquid Sampling System and 3 ORM 10 Liquid Sampling Autoclave Leakage Limits Rev. 7

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