ML24205A080

BWXT Nuclear Operations Group, Inc. – Integrated Inspection Report 07000027/2024002

ML24205A080
Person / Time
Site:	BWX Technologies
Issue date:	07/24/2024
From:	Eric Michel NRC/RGN-II/DFFI
To:	Bittner J BWXT
References
IR 2024002
Download: ML24205A080 (27)

Text

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

BWXT Nuclear Operations Group, Inc.

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

SUBJECT:

BWXT NUCLEAR OPERATIONS GROUP, INC. - INTEGRATED INSPECTION REPORT 07000027/2024002

Dear James J. Bittner:

On June 30, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at BWXT Nuclear Operations Group, Inc. and discussed the results of this inspection with Richard Freudenberger 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, Eric C. Michel, Chief Projects Branch 2 Division of Fuel Facility Inspection Docket No. 07000027 License No. SNM-42

Enclosure:

As stated cc w/ encl: Distribution via LISTSERVJuly 24, 2024 Pitoniak, Noel signing on behalf of Michel, Eric on 07/24/24

ML24205A080

SUNSI Review x Non-Sensitive x Publicly Available x Sensitive Non-Publicly Available

OFFICE RII/DFFI RII/DFFI RII/DFFI RII/DFFI NAME N. Pitoniak M. Doyle C. Oelstrom E. Michel DATE 7/24/24 7/24/24 7/23/2024 7/24/24

U.S. NUCLEAR REGULATORY COMMISSION Inspection Report

Docket Number: 07000027

License Number: SNM-42

Report Number: 07000027/2024002

Enterprise Identifier: I-2024-002-0047

Licensee: Nuclear Operations Group, Inc.

Facility: BWXT Nuclear Operations Group, Inc.

Location: Lynchburg, VA

Inspection Dates: April 01, 2024 to June 30, 2024

Inspectors: L. Cooke, Fuel Facility Project Inspector M. Doyle, Senior Resident Inspector L. Pitts, Sr. Fuel Facility Project Inspector T. Shewmaker, Fuel Facility Project Inspector T. Sippel, Sr. Fuel Facility Project Inspector

Approved By: Eric C. Michel, Chief Projects Branch 2 Division of Fuel Facility Inspection

Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at BWXT Nuclear Operations Group, Inc.,

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

List of Violations

No violations of more than minor significance were identified.

Additional Tracking Items

None.

2 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 10 CFR 70, including 70.24, 70.61, 70.62, and Chapter 11, Management Measures, of the facilitys license application, and applicable licensee procedures.

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

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

• Accident sequences in Uranium Recovery/Ventilation Systems (SAR 15.14, Scrubber Ventilation and Vacuum System in Uranium Recovery) o WED1-2, WED1-3, WED1-4, WED1-8 for Recovery Ductwork Clean Out Inside Tent o S1-1, S1-3, S1-5, S1-6, S1-7, S1-8, S1-9, S1-10, S1-11, S1-12a, S1-12b, S1-13, S1-14, S1-15, DDC1-1, DDC1-2, WED1-1, WED1-7, DSVS-1, DSVS-3, DSVS-5, DSVS-6, and DSVS-7 for Uranium Recovery Main Scrubber and Wet Exhaust Ductwork o DEU1-1, DEU1-13, DEU1-14, DEU1-15, and DEU1-16 for Dry Exhaust Unit/Ductwork (Dispersible Forms of Uranium) o DSVS-1, DSVS-2, DSVS-3, DSVS-4, DSVS-5, DSVS-6, DSVS-7, WED1-7 for Recovery Dry Screw Vacuum System

Review of Safety Controls and Related Programs (IP Section 02.02)

The inspectors reviewed information related to administrative (AD), enhanced administrative (EAD), active engineered (AE), and passive engineered (PE) safety controls or items relied

3 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:

• IROFS in Recovery Ductwork Clean Out Inside Tent o Spacing - Operator controls spacing (AD for nuclear criticality safety) o Volume/Mass - Operator controls size of collection containers (AD for nuclear criticality safety) o Volume/Mass - Defense-in-depth area controls limit volume of containers (AD for nuclear criticality safety) o Volume/Mass - Operator controls the net weight of 2.5-liter containers (AD for nuclear criticality safety)

• IROFS in Uranium Recovery Main Scrubber and Wet Exhaust Ductwork o Geometry - Scrubber tower and recirculation tank installed to meet diameter limit (PE for nuclear criticality safety) o Spacing - Filter housings installed to meet spacing limit (PE for nuclear criticality safety) o Volume - Filter housings installed to meet volume limit (PE for nuclear criticality safety) o Mass/Moderation - Operator limits mass in wet ductwork system through inspections and cleanouts (AD for nuclear criticality safety) o Mass/Moderation - Operator limits mass in exhaust ductwork by inspection high level dissolver (HLD) and low level dissolver (LLD) duct drains for liquid and inspection for obstructions (AD for nuclear criticality safety) o Mass/Moderation - Operator periodically samples scrubber liquid for uranium content during operation (AD for nuclear criticality safety) o Mass/Moderation - Operator maintains solution pH acidic (AD for nuclear criticality safety) o Mass/Moderation - Annual duct survey is performed (AD for nuclear criticality safety) o Mass/Moderation - HLD process uses acid (AD for nuclear criticality safety) o Mass/Moderation - Caustic system is not installed on the scrubber system (PE for nuclear criticality safety) o Mass/Moderation - Operator limits mass buildup in bottom of recirculation tank through inspections and cleanouts (AD for nuclear criticality safety) o Mass/Moderation - Operator limits mass buildup on scrubber tower packing through inspections and cleanouts (AD for nuclear criticality safety) o Mass/Moderation - Water makeup line connects above recirculation tank overflow line (PE for nuclear criticality safety) o Mass/Moderation - Tower air inlet is above scrubber recirculation tank overflow line (PE for nuclear criticality safety) o Mass/Moderation - Tower air inlet is above the tower overflow line (PE for nuclear criticality safety)

4 o Mass/Moderation - Water level in the recirculation tank is maintained below the makeup water inlet and tower air inlet (AE for nuclear criticality safety) o Mass/Moderation - High-High liquid probe in first Recovery Dry Screw Vacuum System vacuum trap automatically shuts down the vacuum pumps (AE for nuclear criticality safety) o Mass/Moderation - Operator shuts down the dry screw vacuum system on high liquid level alarms (EAD for nuclear criticality safety) o Reflection - Ductwork is above the floor and in areas that are not capable of full flooding (PE for nuclear criticality safety)

• IROFS in Recovery Dry Screw Vacuum System o Geometry - Filter housings are installed per approved drawing (PE for nuclear criticality safety) o Spacing - Filter housings are installed to meet spacing limit (PE for nuclear criticality safety) o Geometry - Vacuum traps are installed per approved drawing (PE for nuclear criticality safety) o Spacing - Vacuum traps are installed to meet spacing limits (PE for nuclear criticality safety) o Spacing - Dry Screw Vacuum Pump is installed to meet the spacing limit (PE for nuclear criticality safety) o Volume - Equipment dimensions are fixed in place to ensure favorable geometry (PE for nuclear criticality safety) o Concentration - High-High liquid probe in first Recovery Dry Screw Vacuum System automatically shuts down the vacuum pumps (AE for nuclear criticality safety) o Concentration - Operator shuts down the Dry Screw Vacuum System if the high liquid level alarms (EAD for nuclear criticality safety) o Concentration - Each system connected to the Recovery Dry Screw Vacuum System has a local vacuum trap (PE for nuclear criticality safety) o Moderation - Operator limits the use of moderating material around equipment (AD for nuclear criticality safety)

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 Chapter 11 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:

• walked down systems, IROFS and IROFS components in the Scrubber Ventilation and Vacuum System in Uranium Recovery including the Main Scrubber, scrubber tower, the High-Level Dissolver, Low-Level Dissolver, Recovery Dry Screw Vacuum System, and associated duct work

• reviewed E41-134, Annual Ductwork Survey, and reviewed surveys from 2022 and 2023 for monitoring mass in ductwork and scrubber

5

• reviewed NCS-2017-007, regarding IROFS which prevents excessive moderation into the ductwork system

• reviewed NCS-2017-027, regarding IROFS which ensures ductwork is above the floor and in areas that are not capable of flooding

• reviewed NCS-2008-153, regarding IROFS which ensures filter housings are installed to meet spacing and volume limits

• reviewed QWI 4.1.5, regarding IROFS which ensures pre-filters are installed prior to entering ductwork where accumulation of dispersible uranium is a potential

• reviewed QWI 12.1.16 regarding IROFS which limits volumes of containers

• reviewed the following procedures for implementation of IROFS requirements o OP-1018680 o OP-0061143 o OP-0061150 o OP-0061141 o OP-0061134 o OP-1001828 o OP-0061450 o OP-0061456

• reviewed the following IROFS postings and/or operator aids o 15-09-003, Rev. 4 o 14-14-001, Rev. 1 o 15-05-017, Rev. 1 o 15-9-001, Rev. 0 o 15-12-001, Rev. 0 o 15-05-15, Rev. 0 o 15-05-09, Rev. 4 o 15-05-10, Rev. 0 o 15-05-13, Rev. 0 o 15-05-4, Rev. 4 o 15-05-11, Rev. 0 o 15-05-001, Rev. 2 o Recovery-17, Rev. 1 o Plant-002, Rev. 1

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:

• reviewed OP-0061134 and WO#20324825 and WO#20345594 which tests high level probes in the first Recovery Dry Screw Vacuum System vacuum trap that automatically shuts down the vacuum pumps to ensure no water enters wet exhaust ductwork

6

• reviewed WO#20341530 and WO#20362762 for testing the High-High liquid probe in the first recovery Dry Screw Vacuum System vacuum trap to prevent water entry into the wet exhaust ductwork

• reviewed WO#20362762 and WO#20341530 for operators limiting mass buildup in the bottom of the recirculation tank through inspections and cleaning

• reviewed WO#20361887 and WO#20351594 for operators limiting mass buildup on scrubber tower packing through inspections and cleanouts

• reviewed failure and degradation records for IROFS for the Scrubber Ventilation and Vacuum System in Uranium Recovery area

• reviewed CAP entries/documents for IROFS for the Scrubber Ventilation and Vacuum System in Uranium Recovery area

• reviewed internal audits related to licensing, nuclear criticality safety, emergency preparedness, radiation protection, and nuclear materials control

• reviewed training documents for operators in the Uranium Recovery area and interviewed the Uranium Processing Unit Manager regarding training of IROFS

• reviewed program organizational changes

• observed High Level Dissolver activities as well as TRISO activities and interviewed operators on applicable IROFS

• interviewed NCS staff regarding annual ductwork survey, related calibrations and training regarding applicable IROFS

• reviewed operator log E61-014, which logs scrubber U-235 concentration and pH sample results which limits the mass of uranium in the scrubber

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 Protection, of the facilitys license application, and applicable licensee procedures.

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 license application. Specifically, the inspectors selected the following fire protection features and licensee activities in the Specialty Fuels Fabrication (SFF) and Lynchburg Technology Center (LTC):

• fire detection equipment

• fire suppression equipment

• fire alarms

• manual firefighting equipment

• storage of transient combustibles

• control of ignition sources

7 Preventative Controls (IP Section 02.02)

The inspectors interviewed licensee staff, reviewed documentation, and conducted plant walkdowns to verify the licensees controls for combustibles, ignition sources, and inert atmospheres met the license requirements and applicable requirements in 10 CFR

70. Specifically, the inspectors conducted the inspection activities listed below:

• conducted walkdowns of SFF and the LTC to verify control of combustible materials

• conducted walkdowns and interviews related to controlling inert atmosphere in furnaces

• reviewed HS-03-02, Fire Prevention, Rev. 8

• reviewed HS-03-03, Ignition Source Permits, Rev. 23

• reviewed HS-03-05, Control of Flammable and Combustible Liquids, Rev. 10

• reviewed HS-03-06, Combustible Metals and Pyrophoric Materials, Rev. 13

• reviewed HS-03-07, Control of Systems and Equipment for Fire Protection, Rev. 5

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 license application, or the ISA Summary. Specifically, the inspectors conducted the inspection activities listed below:

• walked down furnace systems in SFF and the LTC

• reviewed maintenance plans for interlocks bases on gas detection, including O2 sensors, LEL detectors, CO detectors, and HCl detectors

• observed alarm station to verify that visual and audible alarms were received during a test

• reviewed smoke detector inspections in the LTC and SFF

• reviewed fire alarm pull station inspections in the LTC and SFF

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 Chapter 7 of the License Application, pre-fire plan, or the ISA Summary. Specifically, the inspectors performed the following activities:

• walked down fire sprinkler systems in SFF and the LTC

• reviewed fire extinguisher inspections in the LTC and SFF

• reviewed fire hydrant inspections in the LTC and SFF

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• walked down moderator restricted areas in SFF

• walked down fire extinguishers in SFF and the LTC

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 license application, pre fire plan, or the ISA Summary. Specifically, the inspectors performed the following activities:

• reviewed HS-FP-018, Fire Barrier/Fire Damper Testing, Rev. 12

• walked down fire barriers in SFF

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:

• walked down two fire engines, medic unit, technical rescue trailer, and hazmat trailer to verify inventory of emergency equipment in accordance with checklists

• observed fire extinguisher training for hot work qualified staff

• reviewed updates to the pre-fire plans for SFF and the LTC

• reviewed RPTWR 04-19, Analysis of the 10 CFR 70.61 Related Effects of a Large Area Fire in Recovery

• reviewed HS-03-08, Employee Fire Response and Firefighting, Rev. 7

• reviewed HS-03-10, Control of Fire Protection System Impairments, Rev. 19

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 corrective action program entries, audits, and self-assessments:

• CA 202400852

• CA 202400707

• CA 202400842

• CA 202300575

• Fire Prevention and IH&S Quarterly Audits o 3Q 2022, 09/23/2022 o 1Q 2023, 03/28/2023 o 2Q 2023, 06/26/2023 o 3Q 2023, 09/23/2023 o 4Q 2023, 12/13/2023 o 1Q 2024, 03/19/2024

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• WO 20351420

88135.02 - Plant Status

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

Radiation Work Permit (RWP) (IP Section 03.09)

The inspectors reviewed and observed the RWP listed below to determine whether the RWP contained the information required by Chapter 4, Radiation Safety of the license application, the Radiation Protection Manual, and implementing procedures:

• RWP 24-0020, WS 350 top cover unload, observed the unloading of WS 350 coating furnace on April 18, 2024

88135.04 - Resident Inspection Program Operational Safety

The inspectors evaluated whether the material condition and as-found configuration of selected site structures, systems, and components, documentation, personnel, and IROFS to verify compliance with 10 CFR Part 70, the license, the safety analysis report (SAR) and/or license application, and licensee policies and procedures; and determine whether they were appropriate, available, and reliable to protect worker and public safety during normal, off-normal, and accident conditions.

Operations Safety Walkdown (IP Section 03.01)

The inspectors evaluated the operational safety of the systems and sub-systems of the listed processes associated element fabrication processes RTRT operations, SAR 15.23.

• reviewed corrective action reports

• performed walkdown of RTRT operations area IROFS

• reviewed operator training qualifications

• reviewed operating procedures

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

The inspectors evaluated the operational status and material condition of fire protection systems, structures, and components (SSCs) to verify compliance with the fire protection program as described in Chapter 7, Fire Safety of the license application, as required.

Fire Area Walkdown (IP Section 03.01)

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

• building GG laundry/supercompactor

88135.19 - Post Maintenance Testing

The inspectors evaluated post-maintenance test activities to verify compliance with license application Chapter 11, Management Measures, and test procedures and work order (WO) instructions to confirm functional capability of the IROFS and/or safety controls following maintenance.

Post-Maintenance Testing (IP Section 03.01)

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

• WO20364410, maintenance and test of contactor evaporator feed supply column level alarm system and interlocks on April 30, 2024

• WO20367879, leak check of heat exchangers for evaporators #1,2,3,4, & 5, SAR 15.09 IROFS on May 15, 2024

88135.22 - Surveillance Testing

The inspectors evaluated IROFS and safety controls that required periodic surveillance and/or calibration tests to ensure they were available and reliable to perform their function when needed, to comply with license application Chapter 11, Management Measures, and the performance requirements of 10 CFR 70.61 and 70.62, and to maintain their operational readiness consistent with the ISA.

Surveillance and Calibration Testing (IP Section 03.01)

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

• annual chemical preparation cycle stop functional test on 05/29/2024

FACILITY SUPPORT

88050 - Emergency Preparedness

The inspectors evaluated selected aspects of the licensees emergency preparedness 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.

Emergency Preparedness Program Review and Implementation (IP Section 02.01)

11 The inspectors selected the following elements that support the implementation of the licensees emergency preparedness program to verify compliance with 10 CFR 70.32(i),

Chapter 8, "Emergency Management" of the license application, and the Emergency Plan. Specifically, the inspectors conducted the following inspection activities:

• reviewed the changes made to revision (Rev.) 36 of the Emergency Plan, and interviewed licensee staff about changes to the emergency preparedness (EP) program

• reviewed a sample of licensee EP procedures, including selected recent revisions (e.g., EPR-01-01, EPR-06-01, HS-ET-01) and associated change packages (e.g., CHG-00010807, CHG-00014744)

• observed training of security emergency directors, reviewed drill documentation and training records

• reviewed recent qualification memos (i.e., HS-2024-037, HS-2024-051) for newly qualified staff, and reviewed a roster showing current personnel qualifications by emergency response position

• reviewed sample of EP training material provided to plant employees (e.g.,

RTP-MAY-2023, RTP-August-2023)

• reviewed sample of monthly EP training for emergency team members, and the 2024 Calendar of emergency team training

• interviewed representative of the Lynchburg General Hospital and a representative of the Concord Rescue Squad

• interviewed site medical personnel

• reviewed current signed mutual aid agreements and memorandums of understandings between the licensee and offsite response agencies

• reviewed records of phone and communication system tests

• reviewed drill packages, including HS-2023-127, HS-2023-139, HS-2024-036, HS-2024-038, to verify that critiques were performed and that issues were captured in the licensee's commitment tracking system, and that the emergency evacuation drill was being performed annually

• interviewed EP staff and walked down emergency equipment at Station One, the emergency operations center (EOC) and the alternate EOC

• reviewed records of inventories of emergency equipment

Identification and Resolution of Problems (IP Section 02.02)

The inspectors reviewed the licensees identification and resolution of emergency preparedness issues to verify compliance with the license requirements. Specifically, the inspectors reviewed the following EP-related corrective action program entries, commitments, and audits:

• CA 202300889, CA 202301169, CA 202301189 and CA 202400904; which include corrective action program entries resulting from audits of the EP program

• COM-102747, 102751, 102752, 102756, 105346, 105353, 105367, 105369, 105985, 108281, 108282, 108285, 109382, 109383, 109384, 109385; which

12 include commitments resulting from critiques of drills and activations, as well as commitments resulting from licensee inventories and equipment checks

• Internal Audit Summary Reports that document audits of EP by the licensee's Quality Control group, including IA-SAR-2023-11-01, and IA-2572C-07-01, and the audit schedule for 2023 and 2024

• the inspectors also interviewed licensee staff about these issues, commitments and audits

Event Review (IP Section 02.03)

The inspectors reviewed the licensees safety-significant and internal events related to emergency preparedness to verify compliance with license requirements and the Emergency Plan. Specifically, the inspectors performed the following activities:

• reviewed documentation of EOC activations, including HS-2023-052, HS-2023-132, HS-2023-133 and HS-2024-071, and interviewed licensee staff concerning these activations and the results of the critiques performed afterwards

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 18, 2024, the inspectors presented the integrated inspection results to Richard Freudenberger and other members of the licensee staff.

• On May 2, 2024, the inspectors presented the operational safety inspection results to Richard Freudenberger and other members of the licensee staff.

• On June 13, 2024, the inspectors presented the emergency preparedness and fire protection inspection results to Rich Freudenberger and other members of the licensee staff.

13 DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or Date Procedure 88020 Corrective Action CA 202301522, Improvement Suggestions from 4QTR Internal Audit 12/6/2023 Documents CA 202301523, CA 202301524, CA202301511 88020 Engineering NCS-1996-017 Nuclear Criticality Safety Technical Work Record 01/26/1996 Evaluations 88020 Engineering NCS-2008-018 Nuclear Criticality Safety Work Record 01/24/2006 Evaluations 88020 Engineering NCS-2008-146 Nuclear Criticality Safety Work Record 09/23/2008 Evaluations 88020 Engineering NCS-2008-153 Nuclear Criticality Safety Technical Work Record 06/26/2009 Evaluations 88020 Engineering NCS-2008-172 Nuclear Criticality Safety Work Record 09/23/2008 Evaluations 88020 Engineering NCS-2017-007 Nuclear Criticality Safety Technical Work Record 01/19/2017 Evaluations 88020 Engineering NCS-2017-027 Nuclear Criticality Safety Work Record 02/08/2017 Evaluations 88020 Engineering NCS-2022-036 Nuclear Safety Release for SER-20-001, Phase 1, Pre- 06/09/2022 Evaluations Operational Requirements: Remove Process Water from Horizontal Columns and Remove Phase Separator Column 88020 Engineering NCS-2024-013 NCS Safety Concern for Excess Mass in WS-145, per 03/13/2024 Evaluations CA202400314 88020 Miscellaneous E41-134 2022 Annual Ductwork Survey 10/21/2022 88020 Miscellaneous E41-134 2023 Annual Ductwork Survey 05/01/2023 88020 Miscellaneous E61-0000659 High Level Trough Dissolver U-235 Log for Trough #1, 4/29/2024 Trough #2, Trough #3, Trough #4 88020 Miscellaneous E61-014 Shiftly scrubber samples in Uranium Recovery for month 04/2024 of April 2024 88020 Miscellaneous NCS Posting Recovery Ductwork Cleanout Inside Tent Rev. 0 B14A-18

14 Inspection Type Designation Description or Title Revision or Date Procedure 88020 Miscellaneous NCS-2015-042 NCS Postings - Dry Screw Vacuum System Filter Rev. 01 Housings & Dry Screw Vacuum System Vacuum Traps 88020 Miscellaneous QWI 12.1.16 Control of Unfavorable Geometry Equipment in the UP Rev. 9 MAA 88020 Miscellaneous QWI 17.1.02 Internal Quality Audits Rev. 24 88020 Miscellaneous Recovery-33 NCS Posting - Recovery Facility Scrubber Catch tank Rev. 0 Discharge Filters 88020 Procedures ADM-NOG-L- Conduct of Operations 04/01/2024 0051 88020 Procedures E41-134 Annual Ductwork Survey Rev. 16 88020 Procedures OP-0061134 Preparation of Chemical Reagents for Uranium Recovery Rev. 37 Operations 88020 Procedures OP-0061141 Low Level Leach Hood Operation Rev. 70 88020 Procedures OP-0061143 Uranium Recovery /Scrubber Operation Rev. 36 88020 Procedures OP-0061150 Inspection and Draining of Recovery Ducts Rev. 33 88020 Procedures OP-0061450 General Safety and Safeguards Guidelines- UPRR Area Rev. 41 88020 Procedures OP-1001828 FAS Interlocks and Furnace Testing Rev. 51 88020 Procedures OP-1018680 Recovery High Level Distillation Rev. 51 88020 Self- 256-1A Licensing License and Permit Changes and Renewals 12/2023 Assessments 258-3H Radiation Procedures, Permits, and Postings Protection 88020 Self- HS-OP-004 att 6 IH&S Quarterly Audits various 2023 Assessments and 2024 88020 Self- IA-2572B-2023- 257-2B Nuclear Criticality Safety, 258-3F Radiation 06/2023 Assessments 06-01 Protection, 259-4D Emergency Preparedness 88020 Self- IA-2572C-2023- 257-2C Nuclear Criticality Safety, 258-3G Radiation 07/2023 Assessments 07-01 Protection, 259-4A Emergency Preparedness 88020 Self- IA-258-3E-05-1 258-3E Radiation Protection 05/2023-Assessments 06/2023 88020 Self- IA-2583C-2023- 258-3C Radiation Protection, 259-4B Emergency 01/2023 Assessments 01-01 Preparedness 88020 Self- IA-NMC-2023 258-3B Radiation Protection, 261-6B1 Nuclear Materials 10/2023 Assessments 01 Control 88020 Self- IA-SAR-2023 SAR 15.27, 256-1B Licensing, 256-1C Licensing, 256-1D 02/2023/03/2023

15 Inspection Type Designation Description or Title Revision or Date Procedure Assessments 01 Licensing, 256-1E Licensing, 257-2A Nuclear Criticality Safety, 259-4E Emergency Preparedness 88020 Self- IA-SAR-2023 Internal Audit Summary Report 12/2023 Assessments 01 88020 Self- IA-SAR-2023 SAR 15.14, 256-1B Licensing, 256-1C Licensing, 256-1D 11/2023-Assessments 01 Licensing, 256-1E Licensing, 257-2D Nuclear Criticality 12/2023 Safety, 259-4E Emergency Preparedness 88020 Work Orders Maintenance Plan SC HLP Dry Screw Pump Column 6M Reco 06/08/2022 and

1. 2591 06/26/2023 WO#20324825 and WO#20345594 88020 Work Orders Maintenance Plan SC Inspect Rec Sump Uranium 1YR Reco 3/28/2024

1. 4231 WO#20341530 and 20362762 88020 Work Orders Maintenance Plan SC Inspect Rec Scrub 6Mon Reco 09/29/2023,

1. 636 03/29/2024 WO#20351594 and WO#20361887 88020 Work Orders MP# 1475 Semi-Annual Inspection of Exhaust Ducts on Bay 14A 10/05/2023, 03/29/2024 88050 Calibration Weather Station Calibration Records Various 2023 Records and 2024 dates 88050 Engineering CHG-00010807 Fix Marking on EPR-01-01 and Update Wording Related Changes to Alarm Conditions for Dosimeters 88050 Engineering CHG-00012185 PLANT EVACUATION DRILL 06/20/2022 Changes 88050 Engineering CHG-00014744 Changes to EPR Procedures 04/30/2024 Changes 88050 Miscellaneous Emergency Plan Rev. 36 88050 Miscellaneous Inventory Records: "Radios and Telephones" 2023 and 2024 dates

16 Inspection Type Designation Description or Title Revision or Date Procedure 88050 Miscellaneous Inventory Records: "EOC Equipment" 2023 Dates 88050 Miscellaneous Inventory Records: "Off Site EOC" 2023 and 2024 Dates 88050 Miscellaneous 2024 Emergency Team Training Calendar 88050 Miscellaneous Emergency Team Training records and documentation for January 2024 88050 Miscellaneous Emergency Team Training records and documentation for February 2024 88050 Miscellaneous Emergency Team Training records and documentation for March 2024 88050 Miscellaneous 2Q2024 Security Supervisor Emergency Director Training 88050 Miscellaneous EPR-06-05-03 Inspection of Emergency Operations Center Readiness, Rev. 30/31/32, Form 3 Various Completion Dates 88050 Miscellaneous HS-2023-052 06/01/2023 EOC Activation for Smoke on RTR Mezzanine Rev. 0 88050 Miscellaneous HS-2023-070 2022 Mutual Aid Agreements & Memorandums of 07/07/2023 Understanding 88050 Miscellaneous HS-2023-087 2023 Annual EMO Training 09/21/2023 88050 Miscellaneous HS-2023-127 2023 Plant Evacuation Drill Results 12/05/2023 88050 Miscellaneous HS-2023-132 EOC Activation Paperwork-Acid Leak in Chem Prep 01/04/2024 Room - 10/26/2023 88050 Miscellaneous HS-2023-133 EOC Activation Paperwork - Bay 5 Arc Flash/Blast Event-Rev. 0 2/27/2013 88050 Miscellaneous HS-2023-139 4Q2022 Quarterly Drill 01/11/2023 88050 Miscellaneous HS-2024-036 2023 Supplemental Drill 03/26/2024 88050 Miscellaneous HS-2024-037 2023 EMO Qualification Document 03/27/2024 88050 Miscellaneous HS-2024-038 1Q2024 Emergency Drill 03/27/2024 88050 Miscellaneous HS-2024-051 EMO Qualification Memo 2024-01 04/22/2024 88050 Miscellaneous HS-2024-071 EOC Activation for SFF Event Rev. 0 88050 Miscellaneous RTP-April-2023 Mt. Athos Site Evacuation 88050 Miscellaneous RTP-August-2023 Emergency Evacuation 88050 Miscellaneous RTP-MAY-2023 Tornado Awareness

17 Inspection Type Designation Description or Title Revision or Date Procedure 88050 Miscellaneous RTP-OCT-2023 Fire Prevention 88050 Procedures EPR-01-01 Emergency Plant Evacuation Rev. 26, 04/30/2024 88050 Procedures EPR-06-01 Emergency Organization Rev. 18, 4/30/2024 88050 Procedures EPR-06-02 Mt. Athos Site Emergency Plan Distribution Rev. 19, 07/19/2023 88050 Procedures EPR-06-04 Emergency Drills Rev. 20, 88050 Procedures EPR-06-05 Inspection of Emergency Operations Center Readiness Rev. 32, 10/30/2023 88050 Procedures EPR-06-05 Inspection of Emergency Operations Center Readiness Rev. 33, 04/30/2024 88050 Procedures EPR-06-07 Plant Evacuation Drill Rev. 8 88050 Procedures HS-ET-003 Inventory and Maintenance of the Emergency Response Rev. 15 Vehicles 88050 Procedures HS-ET-003, Inventory of Medic Unit Rev. 15 Attachment 1 88050 Procedures HS-ET-01 Emergency Team Agreement Rev. 0 88050 Procedures HS-OP-001 Industrial Health & Safety Chg Review Rev. 5 88050 Procedures HS-OP-002 Industrial Health & Safety SER Review Rev. 20 88050 Procedures QWI 2.2.1 Preparation of Quality System Procedures, Instructions, Rev. 24 and Other Documents 88050 Self- IA-2572B-2023- Internal Audit Summary Report, 2nd Quarter 03/07/2024 Assessments 06-01 88050 Self- IA-2572C-2023- Internal Audit Summary Report, 3rd Quarter 03/08/2024 Assessments 07-01 88050 Self- IA-2583C-2023- Internal Audit Summary Report, 1st Quarter 07/27/2023 Assessments 01-01 88050 Self- IA-SAR-2023 Internal Audit Summary Report, 1st Quarter 09/06/2023 Assessments 01 88050 Self- IA-SAR-2023 Internal Audit Summary Report, 4th Quarter 02/08/2024 Assessments 01 88055 Corrective Action CA 202400842 FAS Furnace Shutdown 05/30/2024 Documents

18 Inspection Type Designation Description or Title Revision or Date Procedure 88055 Corrective Action CA 202400852 Rag Fire 05/31/2024 Documents 88055 Corrective Action CA 202400922 IROFS in Incorrect Table 06/11/2024 Documents Resulting from Inspection 88055 Engineering RPTWR 04-019 Analysis of the 10 CFR 70.61 Related Effects of a Large 12/13/2004 Evaluations Area Fire in Recovery 88055 Engineering RPTWR 04-020 Evaluation of a Glovebox Fire to Environmental and 01/06/2005 Evaluations Occupational 10 CFR 70.61 Limits Bay 13A Dry Processes 88055 Fire Plans Mt. Athos Site Pre Fire Plan 03/19/2024 88055 Fire Plans LTC Pre-Fire Plan 11/03/2020 88055 Miscellaneous GP-08 Hands on Live Fire Extinguisher Training 06/11/2024 88055 Miscellaneous HS-ET-003 Inventory of Medic Unit 06/11/2024 Attachment 1 88055 Miscellaneous HS-ET-003 Inventory of Red Truck 06/10/2024 Attachment 2 88055 Miscellaneous HS-ET-003 Inventory of White Truck 06/11/2024 Attachment 3 88055 Miscellaneous HS-ET-003 Inventory of Command Vehicle, Utility Vehicle, Hazmat 06/10/2024 Attachment 4 and Crit Response Trailer 88055 Miscellaneous HS-ET-003 Inventory of the Technical Rescue Trailer 06/10/2024 Attachment 5 88055 Operability B-SNTP-3, Space Nuclear Thermal Propulsion Lab (SNTPL) 07/25/2023 Evaluations Attachment 2 Flammable Gas Monitor Functional Check 88055 Operability B-SNTP-3, SNTPL Flammable Gas Monitor and Glovebox Oxygen 03/26/20204 Evaluations Attachment 3 Sensor Calibraiton 88055 Operability B-SNTP-3, SNTPL Thermal Technology Furnace and Vacuum 05/21/2024 Evaluations Attachment 4 Atmospheres Glovebox Line Safety Device Check 88055 Operability B-SNTP-4 Centorr Furnace System Safety Interlock Testing 12/16/2022 Evaluations Attachment 2 Procedure/Record 88055 Operability B-SNTP-4 Centorr Furnace System Equipment Operation Checklist 12/19/2022 Evaluations Attachment 3

19 Inspection Type Designation Description or Title Revision or Date Procedure 88055 Operability B-SNTP-4 Annual Inspection and Functional Tests 01/26/2022 Evaluations Attachment 5 88055 Operability HS-FP-006 SFF Fire Extinguisher Inspection 05/02/24 Evaluations 88055 Operability HS-FP-006 LTC Building B Fire Extinguisher Inspections 05/15/2024 Evaluations 88055 Operability HS-FP-008 LTC Fire Main Valve Inspections 05/27/2024 Evaluations 88055 Operability HS-FP-008 LTC Sprinkler Flow Alarms Inspection 03/23/2024 Evaluations 88055 Operability HS-FP-008 SFF Sprinkler Flow Alarm Inspection 03/23/2024 Evaluations 88055 Operability HS-FP-008 SFF Fire Main Valves Inspection 05/03/2024 Evaluations 88055 Operability HS-FP-009 LTC Fire Hydrant Inspections 05/27/2024 Evaluations 88055 Operability HS-FP-017 SFF Fire Alarm Pull Station Inspection 07/04/2023 Evaluations 88055 Operability HS-FP-017 LTC Building B Smoke Detector Inspections 0728/2023 Evaluations 88055 Operability MP 1301 FAS and Interlock Testing for WS300 Furnace 09/26/2023 Evaluations 88055 Operability MP 2074 SC FAS/Interlock Test 6" Sintering Furnace 07/26/2023 Evaluations 88055 Operability MP 25369 Oxygen Detectors Calibration 01/08/2024 Evaluations 88055 Operability MP 2538 CO Detectors Calibration 01/08/2024 Evaluations 88055 Operability MP 2542 HCl Detector Calibration 01/15/2024 Evaluations 88055 Operability MP 2550 LEL Detectors Calibration 01/15/2024 Evaluations 88055 Operability MP 3611 LEL Sensor Replacement 01/24/24 Evaluations

20 Inspection Type Designation Description or Title Revision or Date Procedure 88055 Operability MP 5129 SC WS 300 Soot Filter O2 Sensor 05/17/2024 Evaluations 88055 Operability MP 5273 SC O2 Sensor Maintenance for WS 300 02/15/2024 Evaluations 88055 Procedures OP 1015720 Operating Procedure for Coating in the Centorr Furnace Rev. 51 for TRISO 88055 Procedures OP-1001828 Operating Procedure for FAS Interlocks and Furnace Rev. 51 Testing 88055 Procedures QWI 02.1.03 ISA Methodology Rev. 18 88055 Work Orders WO 20351420 Smoke Detector and Pull Station Replacement 08/14/2023 88135.02 Corrective Action CA202400550 NCS - UIR 04/30/2024 Documents 88135.02 Corrective Action CA202400550 Records incomplete/ incorrect 04/08/2024 Documents 88135.02 Corrective Action CA202400764 Other 05/15/2024 Documents 88135.02 Corrective Action CA202400764 Other 05/15/2024 Documents 88135.02 Corrective Action CA202400773 Safety near hit RP- UIR 05/16/2014 Documents 88135.02 Corrective Action CA202400801 maintenance non product 05/23/2024 Documents 88135.02 Corrective Action CA202400831 NCS - UIR 05/30/2024 Documents 88135.02 Corrective Action CA202400833 records incomplete/incorect 05/29/2024 Documents 88135.02 Corrective Action CA202400836 improvement suggestion 05/29/2024 Documents 88135.02 Corrective Action CA202400842 IH&S - UIR 05/30/2024 Documents 88135.02 Corrective Action CA202400843 NCS - UIR 05/06/2024 Documents 88135.02 Corrective Action CA202401006 UIR - NCS 06/25/2024 Documents

21 Inspection Type Designation Description or Title Revision or Date Procedure 88135.02 Corrective Action CA202401031 UIR - I&HS 06/26/2024 Documents 88135.02 Corrective Action N-79 evaluation of unusual incidents, EOC activation on rev 11 Documents 05/06/2024 88135.02 Engineering CR1044862 evaluation of unusual incidents 06/05/2024 Evaluations 88135.02 RWPs RWP 24-0020 WS 350 top cover unload rev. 00 88135.04 Corrective Action CA202201023 UIR - NCS 07/25/2022 Documents 88135.04 Corrective Action CA202300401 UIR - NCS 04/05/2023 Documents 88135.04 Corrective Action CA202300771 UIR - NCS 06/21/2023 Documents 88135.04 Miscellaneous safety analysis element fabrication processes RTRT operations rev. 124 report 15.23 88135.04 Procedures OP-1001079 General safety & safeguards guidelines (RTRT) rev. 6 88135.05 Fire Plans Section 34 Building GG laundry / supercompactor 02/17/2010 88135.17 Procedures E61-692 Pressurized piping and leak test record rev. 01 88135.19 Procedures E61-648 UPRR maintenance work request form rev. 05 88135.19 Procedures E61-691 Checklist for UPRR maintenance work order assessment rev.03 88135.19 Procedures N-307 Lockout/tagout permit rev. 2 88135.19 Work Orders 20364410 sc cont evap feed col level pr urpsm 1y 04/30/2024 88135.19 Work Orders 20367879 Inspection of evaps 1,2,3,4,5 05/14/2024 88135.22 Work Orders 20354637 gp cycle stop func test chem prep 1y rec 05/29/2024

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