ML25223A330

NRC Vendor Inspection Report of Sargent and Lundy LLC No. 99900507-2025

ML25223A330
Person / Time
Site:	99900507
Issue date:	08/26/2025
From:	Kerri Kavanagh, Andrea Keim NRC/NRR/DRO/IQVB
To:	Mcintyre J Sargent & Lundy
References
IR 2025-201
Download: ML25223A330 (1)

Text

Mr. James McIntyre Vice-President & Quality Assurance Director Sargent & Lundy, LLC 55 E. Monroe Street Chicago, IL 60603-5780

SUBJECT:

NUCLEAR REGULATORY COMMISSION VENDOR INSPECTION REPORT OF SARGENT & LUNDY, LLC, NO. 99900507/2025-201

Dear Mr. McIntyre:

From July 14 through July 17, 2025, the U.S. Nuclear Regulatory Commission (NRC) staff conducted an inspection at Sargent & Lundy, LLCs (hereafter referred to as S&L) facility in Chicago, IL. The purpose of this limited-scope inspection was to assess S&Ls compliance with provisions of Title 10 of the Code of Federal Regulations (10 CFR) Part 21, Reporting of Defects and Noncompliance, and selected portions of Appendix B, Quality Assurance Program Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, to 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities.

This technically-focused inspection specifically evaluated S&Ls implementation of the quality activities associated with the consulting, engineering, design, analysis, and supply of safety-related design packages being supplied for new reactor designs and nuclear operating power reactor projects for the U.S. nuclear industry. The enclosed report presents the results of the inspection. This NRC inspection report does not constitute NRC endorsement of S&Ls overall quality assurance (QA) or 10 CFR Part 21 programs.

Based on the results of this inspection, the NRC inspection team found that the implementation of your QA program met the applicable technical and regulatory requirements imposed on you by your customers or NRC licensees. No findings of significance were identified.

In accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding, of the NRCs Rules of Practice, the NRC will make available electronically for public inspection a copy of this letter, its enclosure through the NRC Public Document Room or from the NRCs Agencywide Documents Access and Management System, which is accessible at http://www.nrc.gov/reading-rm/adams.html.

August 26, 2025

J. McIntyre If you have any questions concerning this matter, please contact Ms. Andrea Keim of my staff at (301) 415-1671.

Sincerely, Kerri A. Kavanagh, Chief Quality Assurance and Vendor Inspection Branch Division of Reactor Oversight Office of Nuclear Reactor Regulation Docket No.: 99900507 EPID No.:

I-2025-201-0036

Enclosure:

Inspection Report No. 99900507/2020-201 and Attachment Signed by Kavanagh, Kerri on 08/26/25

ML25223A330 NRR-106 OFFICE NRR/DRO/IQVB NRR/DRO/IQVB NRR/DRO/IQVB NAME JDavis AKeim YLaw DATE 08/21/2025 08/15/2025 08/20/2025 OFFICE NRR/DRO/IQVB NRR/DRO/IQVB NAME FVega KKavanagh DATE 08/21/2025 08/26/2025

Enclosure U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION DIVISION OF REACTOR OVERSIGHT VENDOR INSPECTION REPORT Docket No.:

99900507 Report No.:

99900507/2025-201 Vendor:

Sargent & Lundy, LLC 55 E. Monroe Street Chicago, IL 60603-5780 Vendor

Contact:

James W. McIntyre Vice-President & Quality Assurance Director Email: james.w.mcintyre@sargentlundy.com Phone: 312-269-6530 Nuclear Industry Activity:

Sargent & Lundys scope of supply includes design and general engineering services for new plant construction and operating nuclear power plants in the U.S.

Inspection Dates:

July 14 - 17, 2025 Inspection Team Leader Andrea Keim NRR/DRO/IQVB Inspectors:

Yiu Law NRR/DRO/IQVB Frankie Vega NRR/DRO/IQVB Jacob Davis NRR/DRO/IQVB Trainee Management:

Kerri Kavanagh NRR/DRO/IQVB Branch Chief Approved by:

Kerri A. Kavanagh, Chief Quality Assurance and Vendor Inspection Branch Division of Reactor Oversight Office of Nuclear Reactor Regulation EXECUTIVE

SUMMARY

Sargent & Lundy, LLC 99900507/2025-201 The U.S. Nuclear Regulatory Commission (NRC) staff conducted a vendor inspection at the Sargent & Lundy, LLCs (hereafter referred to as S&L) facility in Chicago, IL, to verify that it had implemented an adequate quality assurance (QA) program that complies with the requirements of Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, to Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Domestic Licensing of Production and Utilization Facilities and 10 CFR Part 21, Reporting of Defects and Noncompliance. The NRC inspection team conducted this inspection on July 14 - 17, 2025.

This was the third NRC inspection at the S&L facility in Chicago, IL since 2000.

This technically-focused inspection specifically evaluated S&Ls implementation of the quality activities associated with design, engineering services, and development and supply of safety-related software for new plant construction and nuclear operating power reactor projects for the U.S. nuclear industry.

These regulations served as the basis for the NRC inspection:

Appendix B to 10 CFR Part 50 10 CFR Part 21 During the course of this inspection, the NRC inspection team implemented Inspection Procedure (IP) 43002, Routine Inspections of Nuclear Vendors, dated February 10, 2023, IP 43004, Inspection of Commercial-Grade Dedication Programs, dated February 10, 2023, and IP 36100, Inspection of 10 CFR Part 21 and Programs for Reporting Defects and Noncompliance, dated February 10, 2023.

The NRC inspection team concluded that S&Ls QA policies and procedures comply with the applicable requirements of Appendix B to 10 CFR Part 50 and 10 CFR Part 21, and that S&Ls personnel are implementing these policies and procedures effectively. The results of this inspection are summarized below.

Inspection Areas The NRC inspection team determined that S&L established its programs for design control, commercial-grade dedication, supplier oversight, nonconforming materials, parts, or components, corrective action, and internal audits, in accordance with applicable regulatory requirements of Appendix B to 10 CFR Part 50. Based on the limited sample of documents reviewed and activities observed, the NRC inspection team also determined that S&L is implementing its policies and procedures associated with these programs. In addition, the NRC inspection team determined that S&L is implementing its 10 CFR Part 21 program for evaluating deviations and reporting defects that could create a substantial safety hazard in accordance with the applicable regulatory requirements.

No findings of significance were identified.

REPORT DETAILS 1.

10 CFR Part 21 Program a.

Inspection Scope The NRC inspection team reviewed Sargent & Lundy, LLCs (hereafter referred to as S&L) policies and implementing procedures that govern the implementation of its Title 10 of the Code of Federal Regulations (10 CFR) Part 21, Reporting of Defects and Noncompliance, program to verify compliance with the regulatory requirements. The NRC inspection team also evaluated the 10 CFR Part 21 postings, and a sample of S&Ls purchase orders (POs) for compliance with the requirements of 10 CFR 21.21, Notification of Failure to Comply or Existence of a Defect and its Evaluation, and 10 CFR 21.31, Procurement Documents.

In addition, the NRC inspection team also verified that S&Ls nonconformance (NCR) and corrective action program (known internally as the Performance Improvement Process [PIP]) provides a link to S&Ls 10 CFR Part 21 program. The NRC noted that S&L have not issued a 10 CFR Part 21 report to the NRC since September 2009 but have issued notices to clients that they are not capable of performing an evaluation of whether defects exist in accordance with their procedures and 10 CFR 21.21(b). The NRC reviewed a sample of the PIPs that S&Ls Engineering Oversite Team (EOT) had dispositioned as Significant Conditions Adverse to Quality (SCAQ) (Level 4/5) or Conditions Adverse to Quality (Level 3) and evaluated for potential 10 CFR Part 21 applicability. It was determined that S&L had effectively dispositioned all reviewed NCRs in a timely manner for potential 10 CFR Part 21 reportability, and taken all required actions The NRC inspection team also discussed the 10 CFR Part 21 program with S&Ls management and technical staff. The attachment to this inspection report lists the documents reviewed by the NRC inspection team b.

Observations and Findings No findings of significance were identified.

c.

Conclusion The NRC inspection team concluded that S&L is implementing its 10 CFR Part 21 program in accordance with the regulatory requirements of 10 CFR Part 21. Based on the limited sample of documents reviewed, the NRC inspection team also determined that S&L is implementing its policies and procedures associated with the 10 CFR Part 21 program. No findings of significance were identified 2.

Design Control a.

Inspection Scope The NRC inspection team reviewed S&Ls policies and implementing procedures that govern the implementation of its design control program to verify compliance with the regulatory requirements of Criterion III, Design Control, of Appendix B to 10 CFR Part

50. The NRC inspection team confirmed that S&Ls procedures provide adequate instructions for the controls of design inputs, outputs, design analyses, records, and organizational interfaces.

The NRC inspection team reviewed a representative sample of costumer POs, design reports, design specifications, engineering drawings, design reviews and design changes for the following safety-related projects supporting both, the operating nuclear reactor fleet and advanced reactor/small modular reactors: (1) Auxiliary Feedwater Controllers replacement for Palisades; (2) GEHs BWRX-300 control rod drive system mechanical design; (3) Subsurface investigation and hydraulic conductivity oversight for the Clinch River site; (4) Geotechnical and seismic subsurface investigations performed for the Dow Seadrift Operations Site; (5) Diesel fire pumps replacement for the Columbia Generating Station.

The NRC inspection team confirmed that S&Ls design control process: (1) was being adequately implemented in accordance with the applicable technical and regulatory requirements; (2) adequately translated technical and quality requirements into applicable specifications, procedures and instructions; (3) effectively controlled design activities by documented instructions and procedures; and (4) accomplished design changes in accordance with the approved procedures.

The NRC inspection team also reviewed S&Ls validation and verification (V&V) process for two of the software developed internally by S&L (i.e., MCHAZARD and HYTRAN). MCHAZARD is used by S&L to perform both deterministic and probabilistic evaluations of hazardous chemical releases. HYTRAN is used by S&L to perform water hammer and steady-state acoustic vibration analyses that compute the time-dependent forces on, and pressures and flow velocities in liquid-filled piping system. The NRC inspection team confirmed that the V&V packages included the purpose and scope, software technical requirements, assumptions, methodology and acceptance criteria, calculations, test results, and comparison of test results against benchmarked results.

The NRC inspection team also discussed the design control program with S&Ls management and technical staff. The attachment to this inspection report lists the documents reviewed and personnel interviewed by the NRC inspection team.

b.

Observations and Findings No findings of significance were identified.

c.

Conclusion The NRC inspection team concluded that S&L is implementing its design control program in accordance with the regulatory requirements of Criterion III of Appendix B to 10 CFR Part 50. Based on the limited sample of documents reviewed, the NRC inspection team also determined that S&L is implementing its policies and procedures associated with the design control program. No findings of significance were identified.

3.

Commercial-Grade Dedication a.

Inspection Scope The NRC inspection team reviewed S&Ls policies and implementing procedures that govern the implementation of its commercial-grade dedication (CGD) program to verify compliance with the requirements of Criterion III, and Criterion VII, Control of Purchased Material, Equipment, and Services, of Appendix B to 10 CFR Part 50.

The NRC inspection team reviewed dedication packages for software (1) PROTO-HX Shell & Tube, (2) PROTO-HX Plate Frame, and (3) ANSYS LS-DYNA; and for calibration of measuring & test equipment (M&TE) for a (1) multifunction calibrator, (2) multimeter, and (3) 4-channel, 200MHz oscilloscope. The NRC inspection team reviewed the POs, the commercial-grade item technical evaluations, receipt inspection reports, certificates of compliance, and technical information. The NRC inspection team evaluated the criteria for the identification of an items safety functions, failure mode and effect analysis (FMEA), selection of critical characteristics and acceptance criteria, and the identification of verification methods to verify effective implementation of S&Ls dedication process.

The NRC inspection team also reviewed S&Ls measures established for the use of the International Laboratory Accreditation Cooperation (ILAC) accreditation process in lieu of performing commercial grade surveys for procurement of calibration and testing services as part of the CGD process. S&L currently implements this process as described in the Nuclear Energy Institute (NEI) Document No.14-05A, Guidelines for the Use of Accreditation in Lieu of Commercial Grade Surveys for Procurement of Laboratory Calibration and Test Services, Revision 1, dated September 2020, which was recognized for use by the NRC in a safety evaluation dated November 23, 2020 (Agencywide Documents Access Management System Accession (ADAMS) No.

ML20322A019).

The NRC inspection team also discussed the CGD program with S&Ls management and technical staff. The attachment to this inspection report lists the documents reviewed and staff interviewed by the NRC inspection team.

b.

Observation and Findings No findings of significance were identified.

c.

Conclusion The NRC inspection team concluded that S&L is implementing its CGD program in accordance with the regulatory requirements of Criterion III and Criterion VII of Appendix B to 10 CFR Part 50. Based on the limited sample of documents reviewed, the NRC inspection team determined that S&L is implementing its policies and procedures associated with the CGD program. No findings of significance were identified.

4.

Supplier Oversight a.

Inspection Scope The NRC inspection team reviewed S&Ls policies and implementing procedures that govern the implementation of its supplier oversight program to verify compliance with the requirements of Criterion IV, Procurement Document Control, and Criterion VII of Appendix B to 10 CFR Part 50.

The NRC inspection team reviewed the nuclear qualified suppliers list (NQSL), a sample of supplier audits, and the most recent POs for these suppliers. For the sample of POs reviewed, the NRC inspection team verified that the POs included, as appropriate: the scope of work, right of access to facilities, and extension of contractual requirements to sub-suppliers. The NRC inspection team also confirmed that the POs adequately invoked the applicable technical, regulatory, and quality requirements.

S&L is a member of the Nuclear Industry Assessment Committee (NIAC), which consists of companies who supply goods and services to the nuclear industry based on a quality program that meets the requirements of Appendix B to 10 CFR Part 50 or NQA-1, Quality Assurance Requirements for Nuclear Facility Applications, and accept 10 CFR Part 21. NIAC develops and maintains procedures and processes necessary to plan, guide, and share supplier audits with its members. S&L uses NIAC audits to support the qualification and maintenance of suppliers. Once a NIAC audit is received, a qualified representative from S&Ls QA organization reviews and evaluates the audit report for completeness and adequacy, in accordance with S&Ls QA program and the appropriateness of the scope and approves the audit report as the basis for including the supplier on the NQSL.

For a sample of supplier audits reviewed, the NRC inspection team verified the audit reports included an audit plan, any findings identified, adequate documented objective evidence of compliance with the applicable requirements, and a review by S&Ls responsible management. In addition, the NRC inspection team verified that the supplier audits were performed by a qualified auditor. Furthermore, the NRC inspection team reviewed a sample of training and qualification records of S&Ls lead auditors and confirmed that the auditing personnel had completed all the required training and had maintained the applicable qualification and certification in accordance with S&Ls policies and procedures.

The NRC inspection team also discussed the supplier oversight program with S&Ls management and technical staff. The attachment to this inspection report lists the documents reviewed by the NRC inspection team.

b.

Observation and Findings No findings of significance were identified c.

Conclusion The NRC inspection team concluded that S&L was implementing its supplier oversight program in accordance with the regulatory requirements of Criterion IV and Criterion VII of Appendix B to 10 CFR Part 50. Based on the limited sample of documents reviewed, the NRC inspection team also determined that S&L was implementing its policies and procedures associated with the supplier oversight program. No findings of significance were identified.

5.

Nonconforming Materials, Parts, or Components and Performance Improvement Process a.

Inspection Scope The NRC inspection team reviewed S&Ls policies and implementing procedures that govern the implementation of its nonconforming materials, parts, or components and corrective actions program (known as the performance improvement program (PIP)) to verify compliance with the requirements of Criterion XV, Nonconforming Materials, Parts, or Components, and Criterion XVI, Corrective Action, of Appendix B to 10 CFR Part 50.

The NRC inspection team attended both of S&Ls EOT meetings where the EOT performs an overview of S&Ls PIPs in various stages of review. The morning meeting discusses new PIPs recently initiated by S&L staff to confirm that they have been issued with all the correct information and assigned to the correct process groups. The afternoon meeting discusses PIPs that have been dispositioned to ensure that the significance level, which determines if an error is an NCR or not, was correctly assigned, as well as that adequate corrective action has been taken or initiated. The NRC inspection team also reviewed a sample of 13 PIPs selected from PIPs created since July 1, 2024. In reviewing these PIPs, the NRC inspection team verified that S&L ensured that all errors were classified as NCRs if applicable, and that all NCRs were adequately documented, dispositioned, verified, and closed with appropriate corrective action taken. The NRC inspection team also verified that S&L performed adequate review on all NCRs to determine if the NCRs were SCAQs or potentially 10 CFR Part 21 reportable. The PIPs were also reviewed to ensure that all activities required by S&Ls relevant procedures were accomplished in a timely manner.

The NRC Inspection team also reviewed the identification of issues and the process for entering issues into the PIP system, the process for dispositioning and correcting issues by relevant staff, and the process for closing. This review was in the service of ensuring that all potential problems are dispositioned and resolved in accordance with S&Ls relevant procedures. The NRC inspection team conducted Interviews with technical and QA staff to verify that the decisions taken to resolve PIPs were adequate and that the actions taken over the lifecycle of a PIP were in accordance with relevant S&L procedures. The NRC inspection team also reviewed the corrective actions documented in the PIP system to ensure they were tracked and their adequacy to the relevant issues.

The documents reviewed by the NRC inspection team as well as a list of S&L staff interviewed are included in the attachment to this inspection report.

b.

Observation and Findings No findings of significance were identified.

c.

Conclusion The NRC inspection team concluded that S&L is implementing its nonconforming materials, parts, or components and corrective action programs in accordance with the regulatory requirements of Criterion XV and Criterion XVI of Appendix B to 10 CFR Part

50. Based on the limited sample of documents reviewed, the NRC inspection team also determined that S&L is implementing its policies and procedures associated with the control of nonconforming materials, parts, or components and PIP programs. No findings of significance were identified.

6.

Internal Audits a.

Inspection Scope The NRC inspection team reviewed S&Ls policies and implementing procedures that govern the implementation of its internal audit program to verify compliance with the requirements of Criterion XVIII, Audits, of Appendix B to 10 CFR Part 50.

The NRC inspection team reviewed a sample of internal audits reports. The NRC inspection team verified that S&L had prepared and approved audit plans that identify the scope and criteria to be audited. The NRC inspection team confirmed that the audit reports contained objective evidence of the areas reviewed and that audit findings were entered into the PIP program. Furthermore, the NRC inspection team verified that lead auditors were adequately qualified.

The NRC inspection team also discussed the internal audit program with S&Ls management and technical staff. The attachment to this inspection report lists the documents reviewed and the staff interviewed by the NRC inspection team.

b.

Observations and Findings No findings of significance were identified.

c.

Conclusion The NRC inspection team concluded that S&L is implementing its internal audits program in accordance with the regulatory requirements of Criterion XVIII of Appendix B to 10 CFR Part 50. Based on the limited sample of documents reviewed and activities observed, the NRC inspection team determined that S&L is implementing its policies and procedures associated with the internal audit program. No findings of significance were identified.

7.

Entrance and Exit Meetings On July 14, 2025, the NRC inspection team discussed the scope of the inspection with Mr. James McIntyre, Vice President & Quality Assurance Director, and other members of S&Ls management and technical staff. On July 17, 2025, the NRC inspection team presented the inspection results and observations during an exit meeting with Mr. McIntyre, and other members of S&Ls management and technical staff. The attachment to this report lists the attendees of the entrance and exit meetings, as well as those individuals whom the NRC inspection team interviewed.

-1 ATTACHMENT 1.

Entrance/Exit Meeting Attendees and Persons Interviewed Name Title Affiliation Entrance Exit Interviewed Andrea Keim Inspection Team Leader Nuclear Regulatory Commission (NRC)

X X

Yiu Law Inspector NRC X*

X*

Frankie Vega Inspector NRC X

X Jacob Davis Inspector-in-training NRC X

X Kerri Kavanagh Branch Chief NRC X

James McIntyre Vice President (VP)&

Quality Assurance (QA) Director Sargent &

Lundy (S&L)

X X

X Alfred Garcia Quality Assurance S&L X

X X

Alec Kusaka Quality Assurance S&L X

X Adam Mrugacz Quality Assurance S&L X

X X

Gabriele Daley Nuclear Program Group (NPG)

Operations Manager S&L X

X Tira L. Seals Executive Assistant S&L X

X Jared Scott Project Director S&L X

Jeff Prendergast Project Director S&L X

X John Masse Quality Assurance Associate S&L X

X Ashley Foote Senior Quality Assurance Associate S&L X

Travis Brosnan Quality Assurance Associate S&L X

X Kaycee Graal Quality Assurance Associate S&L X

Catherine McKnight Quality Improvement Associate S&L X

Shiven Sulkar Chief Nuclear Officer S&L X

X*

Micheal Breisch Project Director S&L X*

Elizabeth Marten Quality Assurance Project Associate S&L X*

X*

Sandra Jannetty Project Director NPG S&L X*

X*

X David Goode Project Director NPG S&L X*

X*

X Mathew Cooper Project Director NPG S&L X*

X*

-2 Name Title Affiliation Entrance Exit Interviewed Robert Gerke Project Director NPG S&L X*

X*

X Micheal Flannagan Project Director NPG S&L X*

Peter Carusona Project Director NPG S&L X*

Quinn Reynolds Project Director NPG S&L X*

X Kevin Morris Quality Assurance Project Associate S&L X*

Maury Pressburger Project Director NPG S&L X*

William Barasa Senior Engineering Manager S&L X*

Brendon Strelow Project Manager S&L X*

Daniel Webb Vice-President S&L X*

Douglass Johnson Sr. Vice-President and Director S&L X*

Todd Baumbach Vice-President S&L X*

• Participated via teleconference 2.

INSPECTION PROCEDURES USED Inspection Procedure (IP) 36100, Inspection of 10 CFR Part 21 and Programs for Reporting Defects and Noncompliance, dated February 10, 2023.

IP 43002, Routine Inspections of Nuclear Vendors, dated February 10, 2023 IP 43004, Inspection of Commercial-Grade Dedication Programs, dated February 10, 2023 3.

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Item Number Status Type Description No previous findings 4.

DOCUMENTS REVIEWED Policies and Procedures SL-TR-1A, S&L Nuclear Quality Assurance Program Topical Report SL-TR-1A, Revision 27, dated April 24, 2025 Standard Operating Procedure (SOP)-0401, Design Drawings, Revision 9, dated July 7, 2022 SOP-0204, Computer Software Quality Policies and Requirements, Revision 17, dated March 25, 2024.

SOP-0402, Design Calculations, Revision 16, dated March 25, 2024 SOP-0403, Control of Design Input, Revision 8A, dated November 13, 2023

-3 SOP-0404, Design Reviews, Revision 5, dated February 25, 2021 SOP-0405, Engineering Evaluations and Reports, Revision 15, dated March 25, 2024 SOP-0406, Control of Design Changes, Revision 4A, dated May 9, 2022 SOP-0203, Project Management, Revision 3, dated April 8, 2021 SOP-0407, Specifications and Bill of Materials, Revision 4, dated March 25, 2024 SOP-0408, Commercial Grade Dedication, Revision 3, dated June 8, 2022 SOP-0601, Project Procurement, Revision 19, dated August 8, 2023 Standard Operating Procedure (SOP)-1401, Performance Improvement Process Revision 18, dated January 16, 2025 SOP-1405, Reporting Defects and Noncompliances Revision 10, dated May 13, 2025 SOP-1602, Records Control Revision 16, dated November 13, 2024 SOP-1701, Audits and Surveillances, Revision 8A, dated July 25, 2016 SOP-1801, Process Definition and Associated Personnel Qualifications Revision 9, dated September 1, 2022 GAS-0204-01, Software Procurement, Revision 6, dated January 19, 2022 GAS-0204-02, Software Control, Revision 3, dated May 20, 2022 GAS-0204-03, Software Acceptance - Non-Nuclear Requirements, Revision 2, dated March 8, 2025 GAS-0204-04, Software Acceptance - Commercial Grade Dedication, Revision 3, dated April 10, 2024 GAS-0204-06, Software Development, Revision 3, dated September 26, 2024 GAS-0603-02, Control of Measuring & Test Equipment, Revision 3, dated December 3, 2024 QAS-0408, Commercial Grade Survey Performance, Revision 1, dated August 21, 2021 QAS-601, Supplier Quality Program Evaluation, Revision 19, dated January 17,2025 QAS-0603, Control of Purchased Services, Revision 0, dated June 27, 2022 QAS-1401, QA PIP Processing, Revision 11, Dated September 2, 2020 QAS-1402, Data Analysis and Trending of PIPs, Revision 8, dated March 1, 2017 QAS-1403, Root Cause Analysis and Apparent Cause Evaluation, Revision 7, dated August 4, 2023 QAS-1404, Common Cause Analysis, Revision 3A, dated November 20, 2014 QAS-1700, Audit, Surveillance, Survey, and Evaluation Planning and Scheduling, Revision 19, dated January 25, 2024 QAS-1701, Qualification and Audit Personnel, Revision 11, dated August 8, 2024 QAS-1702, Audits and Surveillances, Revision 13, dated December 8, 2023 QAS-1703, Nuclear Industry Assessment Corporation (NIAC) Assessments, Revision 2A, dated December 8, 2023 QAS-1704, Auditing Quality Assurance Division Activities, Revision 2, dated May 1, 2023 Design Documents Auxiliary Feedwater Controllers PO No. 98004066, dated March 4, 2024 S&L Proposal No. IV0293-711 Rev. 0 Proposal for Scoping and Requirements Development for Auxiliary Feedwater Controllers Replacement (project Phase 1), dated February 21, 2024 Project Specification No. SPEC-24-00003-PL Auxiliary Feedwater Controllers

-4 Replacement and Positioner Upgrade, Revision 0, dated June 27, 2024 SOP-0404 Design Review Documentation for EC-00000093333, Revision 0 S&L CRN Geotech Vendor Subsurface Investigation Oversight PO No. 7461776, Revision 3, dated June 12, 2024 SL-TVA-2006, Proposal for IV0293.981 Revision 0 CRN Subsurface Hydraulic Conductivity Oversight, dated June 7, 2024 Report SL-019083, Summary of CRN Subsurface Investigation & Hydraulic Conductivity Oversight, Revision 0, August 30, 2024.

Replacement of Diesel Fire Pumps PWP for Contract No. 361873 Diesel Fire Pump Replace, dated February 20, 2024 Specification No. 11308, Fire Protection Pump, Engine, and Controller Procurement Specification, Dated August 31, 2023 (Project No. 10919.246)

Quality Requirements Form SOP-0301-03, Revision 12 for Contract No. 361873, dated March 14, 2023.

Study No. ENW AR 225223225223Diesel Driven Fire Pump Replacement Study, December 19, 2022 Calculation Modification Record Form No. 20254 for Calculation No. E/I-02-90-01 Revision 18, dated Calculation Modification Record Form No. 20270 for Calculation No. 2.06.20 Revision 14 Calculation Modification Record Form No. 20271 for Calculation No. E/I-02-95-01 Revision 9 Calculation Modification Record Form No. 20272 for Calculation No. E/I-02-87-07 Revision 14 Calculation Modification Record Form No. 0000020181 for Calculation No. FP-02-10-01 Calculation Modification Record Form No. 20660 for Calculation No. DO-2542-2 Design Equivalent Change Package Replacement of Diesel Driven Fire Pumps, Revision 001, May 27, 2025 Mechanical Design - Control Rod Drive System P.O. No. 437146871, Revision 11, dated August 9, 2024 Project proposal IV0293.418, Revision 3, dated November 2023 Drawing Number 006N5923, Revision 3, June 22, 2022 SP0-S&L-A00-NNN-TPLN-PM-0001 BWRX-300 Standard Plant Design S&L Project Manual for Project No. A14975, Revision 0, dated April 7, 2024 SP0-S&L-G12-RZZ-LEQP-MM-0001 associated with Project No. A14975.012, BWRX-300 Control Rod Drive System Equipment Lists SP0-S&L-G12-RZZ-LINE-MM-0001 associated with Project No. A14975.012, BWRX-300 Control Rod Drive System Pipeline List Mechanical Design - Primary Containment Cooling System PO/SOW Doc-0016-8383 S&L Engineering Services - BWRX-300 MNI Reactor Building Engineering & Design to Support BL2 Revision 7 S&L proposal IV0293.418, Revision 3 for GE BWRX-300 MNI Reactor Building Engineering and Design Support, dated November 20, 2023 Geotechnical and Seismic Subsurface Investigation Proposal No. IV0293.334, dated May 1, 2023

-5 PO 000002598, dated June 2, 2023 PO-0045798, dated June 13, 2023 Procurement plan for Project No. A13766.124, dated June 9, 2023 Specification No. X-2002, Xe-100 Long Mott Project Subsurface Exploration for project No. 13766.124, dated September 15, 2023 Software - Hytran Users Manual for HYTRAN (Hydraulic Transient Analysis Program), July 2022 Software Configuration Control Submittal Form GAS-0204-02-01 for HYTRAN, dated November 15, 2022 Software User Documentation Form GAS-0204-02-03 for HYTRAN Software Verification & Validation Report Certification Form GAS-0204-06-01 for HYTRAN, November 14, 2022.

HYTRAN v2.0 Validation Report, Revision 0 Software - McHazard Calculation No. 2019-03163, Revision 1 Software Verification and Validation Report for Monte Carlo Hazard Analysis Program-MCHazard, November 11, 2023 Software Configuration Control Submittal Form GAS-0204-02-01 for Monte Carlo Hazard Analysis Program, November 11, 2023 Software user documentation Form GAS-0204-02-03 for McHazard Software Verification & Validation Report Certification for Monte Carlo Hazard Analysis Program (MCHAZARD), November 08, 2023 Software Requirements Specification and Software Design and Test Plan, November 06, 2023 Performance Improvement Process (PIP) (i.e., Corrective Action Process)

PIP 2022-1053 PIP 2023-1297, 2133, 2599, PIP 2024-0063, 0096, 0335, 0339, 1266, 1775, 2711, 2712, 2735, 2924, 3110, 3111, 3112 PIP 2025-0055, 1350 Commercial Grade Dedication Packages CGD package for software PROTO-HX Shell & Tube CGD package for software PROTO-HX Plate & Frame CGD package for software ANSYS LS-DYNA CGD package for a Fluke Multifunction Calibrator CGD package for a Fluke Multimeter CGD package for Agilent/HP Oscilloscope ILAC Calibration Certificate for a sub-supplier Audit Reports Evaluation Report No. 2023-010, dated March 29, 2023 Evaluation Report No. 2024-006, dated October 10, 2024 Audit Report No. 2021-075, dated January 17, 2022

-6 Audit Report No. 2024-002, dated June 6, 2024 Audit Report No. 2025-000, dated April 7, 2025 NIAC Audit Report No. 2023-046, dated December 5, 2023 NIAC Assessment Evaluation Report No. 2024-074, dated September 27, 2024 NIAC Surveillance Report No. 2023-071, dated February 29, 2024 Surveillance Report No. 2024-073, dated January 30, 2025 Audit Report No. 2023-050 dated February 15, 2024 Audit Report No. 2024-010 dated April 5, 2024 Audit Report No. 2024-051 dated December 16, 2024 Audit Report No. 2024-052 dated December 20, 2024 Miscellaneous Nuclear Safety Review Committee Minutes January 15 with Updates (AutoPIPE), Dated January 15, 2024 Tracking of AUTOPIPE Critical Error Client Notifications [UNKNOWN DATE]

NPG PIPs since 7-1-2024, Dated July 8, 2025 PIP 2023-1297 Impact Evaluation and Extent of Condition Report, dated October 25, 2023 Email communication for PIP 2023-1297 Start of 60 day 10 CFR Clock, dated September 18, 2023 Email communication for PIP 2023-1297 Documentation of Discussion, dated September 23, 2023 Sargent & Lundy Nuclear Qualified Suppliers List, Revision 215, dated July 10, 2025 Quality Assurance Division - Overview Schedule for the period of 10/01/2024 to 12/31/2026, dated February 28, 2025 Training and Qualification Records Qualification Records 6 design engineers: J Gerol, S Micic, D Nielson, S Pfeiffer, J Prendergast, D Stamatov Qualification Records for 19 commercial grade dedication personnel: A. Brown, L.

Cleveland, J. Coats, T Hausman, P. Hoang, M Idell, P. Kohler, K. Mayer, T. McFall, K.

Miller, A. Mrugacz, M. Nena, D. Nevill, R. Peterson, B. Rovagnati, A. Stanford, M.

Summers, J. Wakeland, R. Young Qualification Records for 5 Lead Auditors: T. Brosnan, A. Foote, K. Graal, A. Kusaka, A.

Mrugacz