ML25349B017

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Framatome - Integrated Core Inspection Report 07001257/2025003 and Orr Report 07001257/2025007
ML25349B017
Person / Time
Site: Framatome ANP Richland
Issue date: 12/16/2025
From: Eric Michel
NRC/RGN-II/DFRSS/FOB2
To: Vance B
Framatome
References
IR 2025007, IR 2025003
Download: ML25349B017 (0)


Text

Brian Vance Site Manager Framatome 2101 Horn Rapids Road Richland, WA 99354

SUBJECT:

FRAMATOME - INTEGRATED CORE INSPECTION REPORT 07001257/2025003 AND ORR REPORT 07001257/2025007

Dear Brian Vance:

This letter refers to the Nuclear Regulatory Commission (NRC) inspection activities conducted from June 30 to September 30, 2025, for the Framatome facility. On July 10, July 17, and September 11, 2025, the NRC inspectors discussed the results of these inspections with 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.

Due to the temporary cessation of government operations, which commenced on October 01, 2025, the NRC began operating under its Office of Management and Budget-approved plan for operations during a lapse in appropriations. Consistent with that plan, the NRC operated at reduced staffing levels throughout the duration of the shutdown. However, the NRC continued to perform critical health and safety functions. On November 13, 2025, following the passage of a continuing resolution, the NRC resumed normal operations. However, due to the 43-day lapse in normal operations, the Office of Nuclear Materials Safety and Safeguards granted Region 2 an extension on the issuance of the calendar year 2025, 3rd quarter integrated inspection reports normally issued by November 15, 2025, to December 31, 2025. The NRC will resume the routine cycle of issuing inspection reports on a quarterly basis beginning with the calendar year 2025, 4th quarter integrated inspection reports, which will be issued 45 days after the 4th quarter ends on December 31, 2025.

December 16, 2025

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 Fuels Oversight Branch 2 Division of Fuels, Radiological Safety, and Security Docket No. 07001257 License No. SNM1227

Enclosure:

As stated cc w/ encl: Distribution via LISTSERV Signed by Michel, Eric on 12/16/25

ML25349B017 X

SUNSI Review X

Non-Sensitive

Sensitive X

Publicly Available

Non-Publicly Available OFFICE:

RII/DFRSS RII/DFRSS NAME:

M. Day E. Michel DATE:

12/16/25 12/16/25

Enclosure U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number:

07001257 License Number:

SNM1227 Report Number:

07001257/2025003 and 07001257/2025007 Enterprise Identifier:

I2025-003-0028 and 1-2025-007-0003 Licensee:

Framatome Facility:

Framatome Location:

Richland, WA Inspection Dates:

July 7-11, 2025; July 14-18, 2025; and September 8-12, 2025 Inspectors:

M. Day, Fuel Facilities Inspector G. Goff, Fuel Facilities Inspector J. Grice, Fuel Facilities Inspector N. Peterka, Sr. Fuel Facilities Inspector T. Shewmaker, Fuel Facilities Inspector K. Sullivan, Fuel Facilities Inspector C. Taylor, Sr. Fuel Facility Project Inspector C. Oelstrom, Fuel Facilities Inspector Approved By:

Eric C. Michel, Chief Fuels Oversight Branch 2 Division of Fuels, Radiological Safety, and Security

2

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a core inspection and operational readiness review at Framatome, 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.

3 PLANT STATUS The Framatome facility converts uranium hexafluoride (UF6) into uranium dioxide (UO2) for the fabrication of low-enriched fuel assemblies used in commercial light-water reactors. During the inspection period, normal production activities were ongoing. In addition to normal activities, construction work was occurring for the Advanced Fuel Manufacturing (AFM) project to increase sitewide enrichment from 5 wt. to 6.5 wt.% U235.

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 88015 - Nuclear Criticality Safety The inspectors evaluated selected aspects of the licensees nuclear criticality safety (NCS) program to verify compliance with selected portions of 10 Code of Federal Regulation (CFR) 70, including 70.61, 70.62, and 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 nuclear criticality safety analyses (NCSAs), and associated assumptions and calculations, to verify compliance with 10 CFR 70 and applicable sections of the license application, including portions of 3.1.4, 3.1.5, 3.1.6, 5.3.4, and 5.4. Specifically, the inspectors interviewed licensee staff, walked down systems, and reviewed the following NCSAs:

E04-NCSA100, ADU Process Off Gas System, Version 14, including the review of the what-if analysis, double contingency analysis, items relied on for safety (IROFS) control tables, SCALE computer models, and accident sequences 1.2, 4.1, and 5.2 E04-NCSA-545, Product Development Test Facility, Version 4, including review of what-if analysis, normal, credible abnormal, and non-credible accident sequences E04-NCSA-960, HVAC Building Exhaust, Version 43, including the review of what-if analysis, normal, credible abnormal, and non-credible accident sequences and the IROFS that were established to prevent criticality

4 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, plant walkdowns, and interviews to verify compliance with 10 CFR 70 and applicable sections of the license application, including portions of 11.2.2. Specifically, the inspectors interviewed licensee staff and reviewed the following controls, and their management measures, associated with the NCSAs listed above:

IROFS 104, an administrative control on geometry/moderation for powder/rod spills, and associated procedures IROFS 3302, an administrative control on geometry for rod height, including a field walkdown and associated NCS posting IROFS 4506, a passive engineered control on moderation for the high efficiency particulate air (HEPA) filter housing to prevent moderator intrusion; including a field walkdown IROFS 4512, an active engineered control on mass for the HEPA filters based on differential pressure, and associated surveillances IROFS 4520, an administrative control on mass for the HEPA filters based on either frequency or differential pressure readings, and associated procedures 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 5.3.10, 5.3.11, and 5.5. Specifically, the inspectors performed the following activities:

reviewed the 2025 criticality safety audit schedule and a sample of recently completed audits for the facility interviewed criticality safety staff concerning criticality hazards and control methods, including monitoring for long-term accumulations in the ventilation systems interviewed criticality safety staff concerning criticality hazards and control methods, including enrichment and geometry controls for the Product Test Development Facility observed an NCS engineer conduct an audit of the I3G storage building interviewed I3G and Product Development Test Facility area operators and employees concerning criticality hazards and control methods, including IROFS in the areas and the associated operating procedures Criticality Programmatic Oversight (IP Section 02.04)

The inspectors reviewed NCS program procedures and NCS staff qualifications to verify compliance with 10 CFR 70 and applicable sections of the license application, including portions of 2.2.5.1. Specifically, the inspectors observed activities, reviewed documents, and interviewed licensee staff concerning the following:

5 reviewed qualification and training records for the most recently qualified criticality safety analyst interviewed NCS staff concerning the NCS review of changes, including changes to operating procedures that may affect NCS, and changes to the facility the most recent revision to licensee procedure E04-06-002, Routine Nuclear Criticality Safety Audits Criticality Incident Response and Corrective Action (IP Section 02.05)

The inspectors reviewed the implementation of the corrective action program (CAP) to verify compliance with 10 CFR 70 and applicable sections of the license application, including Section 5.5. Specifically, the inspectors performed the following activities:

reviewed selected issues entered into the CAP pertaining to criticality safety and audit findings reviewed select testing records for the CAAS detector calibrations and horn checks for 2024 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, and 70.62, as well as 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 NCS, radiation safety, fire safety, and/or chemical safety based on the information provided in the 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:

Lube Blend Press Feed - Line 6 (System 360) accident 360-1.6, water due to firefighting from adjacent area causes criticality event accident 360-1.8, significant roof or pipe leak in subject area accident 360-1.12.1, operator error transfer to unfavorable geometry without neutron absorbers accident 360-1.14, operator error causes wrong amount of additive due to mix-up (Not Credible) accident 360-2.5, mechanical failure results in drum failure Warehouse 8/13F; Operations Scrap Warehouse 7 (Systems 773 & 776); Planar Array Storage of SNM in Sea-Land Containers and Warehouses (System 777)

6 accident 776-1-2, four containers palletized array in a specified location is filled with more than double a safe batch of uranium dioxide (UO2) accident 776-1.6, four containers palletized array stored in a specified location with one container great than double a safe batch and also contains > 4 wt.%

water accident 776-2.3, loss of container spacing for storage rack and collapsed due to impact by a forklift with moderation of water exceeding 5 vol%

accident 776-2.23, multiple containers stack error or adjacent to each other in a specified location and containers contain significantly more than a safe batch of UO2 with water moderation > 4 wt.%

accident 776-5.1, loss of spacing of ash pails occurs when a Section of a storage rack collapses after weakened by a large fire accident 776-5.2, loss of ash pail spacing occurs when a portion of a storage rack collapses due to impact by a forklift accident 777-5.1, HEPA filters stored inappropriately in sea-land container with water moderation Uranyl Nitrate Building (System 720) accident 720- 3.1.1, catch basin pump fails on, results in overfill into unfavorable geometry ductwork and concentrated by evaporation accident 720-8.1.1, impact by powered equipment into tanks causes rupture of a valve/pipe or tank puncture with catastrophic loss > 10,000 gal of uranyl nitrate (UN) solution accident 720-8.1.2, impact by powered equipment into multiple tanks breaks off a valve/pipe or punctures the tanks causing a catastrophic loss > 10,000 gallons of UN solution; floods building and overflows outside such that the UN solution concentrates in the soil or there is significant accumulation in unfavorable geometry accident 720-8.6.1, normal building heat fails off, and low external temperature freezes the UN solution increasing UN solution concentration >

280 g U/l Review of Safety Controls and Related Programs (IP Section 02.02)

The inspectors reviewed information related to safety controls or 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:

Lube Blend Press Feed - Line 6 (System 360)

IROFS 1105.01, moderation control accomplished by administrative action (Admin)

IROFS 1402, mass control accomplished by enhanced administrative control (EA)

IROFS 1502, neutron absorber control accomplished by passive engineered control (PEC)

7 IROFS 1505, moderation control accomplished by PEC IROFS 1508, moderation control accomplished by PEC IROFS 1509, mass/moderation controls accomplished by accomplished by administrative action (Admin)

IROFS 1510, moderation/geometry control accomplished by EA IROFS 1512, neutron absorber control accomplished by administrative action (Admin)

IROFS 1513, mass control accomplished by EA IROFS 1611, moderation control accomplished by PEC IROFS 1614, moderation control accomplished by PEC IROFS 2417.01, secondary reviews of additives accomplished by administrative action (Admin)

IROFS 2419, moderation control accomplished by PEC ROFS 4502, moderation control accomplished by administrative action (Admin)

IROFS 4503, moderation control accomplished by administrative action (Admin)

IROFS 4712, moderation controls accomplished by administrative action (Admin)

IROFS 5302.10, moderation control accomplished by PEC Operations Scrap Warehouse 7; Warehouse 8/13F (System 776 & 773)

IROFS 105, mass control accomplished by administrative action (Admin)

IROFS 1402, mass control accomplished by EA IROFS 1403, mass control accomplished by EA IROFS 2106, moderation control accomplished by administrative action (Admin)

IROFS 2107, geometry control accomplished by administrative action (Admin)

IROFS 3710.10, geometry control accomplished by PEC IROFS 4909, moderation control accomplished by PEC IROFS 5503, mass/moderation control accomplished by PEC Planar Array Storage of SNM in Sea-Land Containers and Warehouses (System 777)

IROFS 4502, moderation control accomplished by administrative action (Admin)

IROFS 4503, moderation control accomplished by administrative action (Admin)

IROFS 4907, mass control accomplished by administrative action (Admin)

IROFS 4908, moderation control accomplished by administrative action (Admin)

IROFS 4909, moderation control accomplished by PEC Uranyl Nitrate Building (System 720)

IROFS 715, mass control accomplished by active engineered control (AEC)

IROFS 716, mass control accomplished by administrative action (Admin)

IROFS 717, mass control accomplished by administrative action (Admin)

IROFS 718, concentration control accomplished by EA IROFS 723, concentration control accomplished by EA IROFS 725, concentration control accomplished by ACE IROFS 740, use of protective measures accomplished by PEC IROFS 747, powered equipment location and movement at specified locations accomplished by administrative action (Admin)

IROFS 751, geometry control accomplished by PEC

8 IROFS 752, concentration control accomplished by PEC IROFS 753, concentration control accomplished by AEC IROFS 816, training for hazardous chemical release accomplished by administrative action (Admin)

Site Wide IROFS 0.20, generic requirements for equipment dimensions and materials (PEC)

IROFS 0.24, generic requirements building and equipment design to prevent leaks from natural phenomenal hazard (PEC)

IROFS 4530, Final HEPA filters are constructed of flame-retardant materials (PEC)

Implementation of Safety Controls (IP Section 02.03)

For the selected safety controls listed above, the inspectors reviewed management measures to verify proper implementation in accordance with 10 CFR 70 and applicable sections of the license application This review was performed to verify that selected safety controls or IROFS were present, available, and reliable to perform their safety function and that the design-basis assumptions were reflected in the actual conditions in the field. The inspectors conducted the following activities to verify the implementation of selected safety controls:

walkdown of the following areas:

Uranyl Nitrate Building (UNB) and observed new piping installation throughout the building and equipment upgrades Planar array system for Warehouse #7, sea-land containers numbered 1 through 6, and storage of new HEPA filters in temperature-controlled areas Lube Blend Press Feed Area walkdown of the Uranium Oxide (UO) building south bundle new storage addition (IROFS.24) observed the implementation of the following IROFS during a lube blend feed tumbling evolution (Order # 20266862):

IROFS 0.20 IROFS 1105.01 IROFS 1509 IROFS 1510 IROFS 1512 IROFS 1611 IROFS 1614 IROFS 2417.01 IROFS 2419 IROFS 4712 IROFS 5302.01

9 during walkdown of sea-land containers #1-6, observed the implementation of the following IROFS IROFS 1413.01 IROFS 1614 IROFS 4502 IROFS 4505 IROFS 4902 IROFS 4903 IROFS 4905 IROFS 4909 observed sea-land containers for visible leakage and/or flooding after a twenty-minute rain event to verify implementation of IROFS 1614 and 4909 that protects for water intrusion inside containers reviewed inventory sheets for sea-land container #1 to verify batches inside containers were less than the required limit of 641 grams of uranium 235 observed condition and position of bollards/guards in the 13F Warehouse (IROFS 5503) interviewed operators and radiation staff regarding hazards associated with accident sequences and IROFS identified in Sections 02.01 and 02.02 interviewed the project manager to discuss the design requirements associated with the UO building new south bundle storage addition (IROFS

.20 and.24) interviewed Air Balance Supervisor to discuss plant ventilation and HEPA filter maintenance activities reviewed the following Justified Continued Operation (JCO):

JCO 2025-004, bypass of heater interlock V3-101 JCO 2025-002, phone system out of service JCO 2024-002, disabled proportional sampler JCO 2023-003, ammonium diuranate (ADU) lube failure walkdown of HEPA filter sea-land containers to verify implementation of moderation control (IROFS 4908) walkdown of HEPA filter storage to verify HEPA filters are built out of fire-retardant material (IROFS 4530)

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 engineered change notice (ECN) 9138 and structural calculations for the UO building new south bundle storage addition (IROFS.20 and.24) reviewed the following procedures to verify established limits and controls for IROFS identified in Section 02.02:

E04-NCSA-360, Lube Blend Press Feed, Version 19

10 E04-NCSS-G07, Building and Facilities NCS Design Requirements Including Initial Conditions and Bounding Assumptions, Version 15 E04-NCSA-776, Warehouse #7 (13 G), Version 18 E04-NCSA-777, Planar Array Storage of SNM in Sea-Land Containers and Warehouse SOP-40498, Planar Array Storage of SNM in Sea-Land Containers and Warehouses, Revision 8.0 E04-NCSS-GO6, Fire Prevention and Firefighting, Version 34 E04-NCSA-773, UNH Warehouse (13F), Version 11 SOP 41145, Scrap Uranium Recovery Facility (SURF) UNB Processing SOP 41026, UNB Tank to Tank Transfer reviewed the following training documents for UNB on the job training skills evaluation training continuing training evaluation system 720 - UN Storage Exam UNB Operator Exam reviewed DWG-CSA-607,509; AREVA Site General Arrangement Bleu Pelletizing Powder Prep, Rev. 007, Sheet 101, to verify that approved combustible locations on the drawing were identified for Gadolinium Line 6 lube blend area (IROFS 4503 and IROFS 0.20) reviewed training records for manufacturing operators, ID T9128 and ID T6184, to verify current training in the Lube Press Feed area reviewed Certificate of Conformance (COC); Order Number: 1034338-1 for drums used in drum tumbler Lube Press Feed Area to verify 45-gal drum passed specifications on COC (IROFS 403) reviewed E04-09-001, HRR Criticality Accident Alarm System Coverage Demonstration, Figure 14, Zoomed View of Criticality Detector Coverage for Detector located in the UF6 Scale House Version 8 to verify sea-land containers were covered by area in the criticality alert system reviewed the following documents for UNH Warehouse (13F):

ECN 9054; dated 8/26/25; Field Change Notices (FCNs) 1 dated 7/09/24, FCN 2 dated 10/9/24 and FCN 3 dated 6/12/25, for Warehouse (13F) planar array system to verify changes adhered to generic requirements (IROFS 0.20 and 0.24)

Moisture Content C773P001; 13F Scrap Storage Prot. 6-month IROFS Scale Weight Indicator 13 F Storage; dated 5/1/25 (IROFS 1403)

C773P002, Order 13677415; Heat Test; IROFS Bldg. UN & Service Equipment dated 10/01/2024 (IROFS 3710.10)

DWG-CSA-614, 638, Revision 0 (IROFS 4909)

C773P002 Storage Racks WHS 13F 1 year inspection dated 7/28/25 Fire Safety Inspection 1 month; Order 13723508; dated 8/27/25 location SAF-FGAS reviewed the following preventive maintenance (PM) documents for dry conversion heating ventilation and air conditioning system:

PM004075 PM004076 PM004077

11 reviewed the following condition reports (CR):

CR 2024-3536 CR 2025-0015 CR 2025-0596 CR 2025-0655 CR 2025-0820 CR 2025-1022 CR 2025-2105 reviewed Annual Configuration Control Audit Report - 2024 (JGM-24-001) to verify audit was conducted in accordance with Environmental Health and Safety and Licensing (EHS&L) Audit guide E12-03-062 RADIOLOGICAL CONTROLS 88045 - Effluent Control and Environmental Protection The inspectors evaluated selected aspects of the licensees environmental protection program to verify compliance with selected portions of 10 CFR 20, Part 40, Part 61, and Part 70, and the facilitys license application.

Program Implementation (IP Section 02.01)

The inspectors reviewed significant changes to the effluent control and environmental protection program, discussed new unplanned releases or contamination identified, and screened the CAP in order to verify the environmental protection program was implemented in compliance with license requirements. Specifically, the inspectors reviewed the following documents and/or discussed the following areas:

reviewed the latest organizational chart for the EHS&L organization interviewed the EHS&L Manager to confirm no substantial organizational or substantive program changes had occurred since the last inspection interviewed the Environmental Program Manager to verify personnel changes in the Environmental Program Department since the last NRC inspection were in accordance with license application requirements interviewed the Environmental Program Manager to verify there were no unplanned releases of contamination to the environment or subsurface of the facility reviewed the following CAP entries to verify licensee identified issues in the area of Environmental Protection, entered them into the CAP, and corrected the conditions as required by license, procedure, and/or NRC requirements. The following CRs were reviewed:

CR 2025-1122 CR 2024-2598 CR 2024-1514 CR 2024-2598-01 CR 2025-1849 CR 2025-0015 CR 2025-0061

12 CR 2025-1763 CR 2025-0135 CR 2025-1049 CR 2024-3636 attended ADU/MURS daily morning meeting Procedures (IP Section 02.02)

The inspectors selected a sample set of procedures changed since the last inspection and, if possible, observed the procedures in use to verify that safety-significant changes to procedures in the area of environmental protection were in compliance with license requirements and 10 CFR 20. Specifically, the inspectors completed the following activities:

reviewed the following procedures:

  • SOP-40031, Waste Effluent Monitoring & Sampling, Version 20.0
  • SOP-40032, Radioactive Gaseous Effluent Sampling, Version 31.0
  • SOP-41096, Analysis of Ions by Ion Chromatography, Using ICS1600, Version 5.0
  • E06-05-001, Environmental Standards, Revision 2.0
  • 1703-88, US Fuel CAP, Revision 7 1703-88-F03, Condition Report: EHS&L Condition Template, Revision 0 observed daily sample collection and weekly composite sample collection (SOP-40031)

Audits and Quality Assurance (IP Section 02.03)

The inspectors reviewed procedures associated with the conduct of audits and assessments along with completed third-party and self-assessed audits and resulting corrective action entries assessed with the environmental protection program since the last inspection to verify compliance with license application requirements. Specifically, the inspectors completed the following activities:

reviewed Semiannual Environmental Monitoring Audit Summary (Audit No.

EMA-62) reviewed E12-03-042, Environmental Surveillance Results reviewed E05-01-026, The ALARA Report - January 1, 2023 - December 31, 2023, dated July 30, 2024 reviewed BSK:24:001, Annual Radioactive Waste Handling Audit, dated April 25, 2024 Event Review (IP Section 02.04)

The inspectors reviewed the licensees evaluation of safety-significant events in the area of environmental protection to verify compliance with 10 CFR 20 and license application requirements. Specifically, the inspectors reviewed the following:

reviewed various CRs in the area of environmental protection (see Section 02.01 and Document Reviewed Section)

13 reviewed CR 2024-1514 to verify corrective actions were implemented regarding calculational errors in the semiannual effluent reports required for submittal to the agency reviewed SOP-41159, HST Incident Response, Version 5.0, for recent updates and/or substantial changes Training (IP Section 02.05)

The inspectors reviewed the licensees training program in the area of environmental protection to verify compliance with license application requirements. Specifically, the inspectors reviewed the following:

reviewed various training and qualification records for operators and environmental health and safety staff interviewed training coordinator about procedures to verify operator training stays current Radioactive Liquid Effluents (IP Section 02.06)

The inspectors observed operations, reviewed sample collection and analysis procedures, reviewed radiological effluent monitoring reports and monitoring records, and discussed the radioactive liquid effluent results with licensee staff to verify compliance with aspects of 10 CFR 20.2103 and the license application. Specifically, the inspectors completed the following activities:

reviewed the following procedures:

E-06-07-009, Groundwater Monitoring, Version. 2.0 SOP-40031, Waste Effluent Monitoring, Version 18.0 reviewed a sample of liquid effluent discharge records for 2023 and 2024 for the plant effluent monitoring station to verify results did not exceed the action levels and effluent concentration values in 10 CFR 20, Appendix B, Table 2 reviewed a sample of liquid effluent discharges records for liquid processes to the Wastewater Treatment Facility tanks to verify radioactive concentration in these discharges did not exceed action levels and effluent concentration values in 10 CFR 20, Appendix B, Table 2 Municipal Sanitary Sewer (IP Section 02.07)

The inspectors reviewed records related to the release of liquid effluents to sanitary sewers to verify compliance with 10 CFR 20.2003 and the license application. Specifically, the inspectors completed the following activities:

reviewed a sample report from the plant effluent monitoring station (PEMS) observed the collection of the PEMS composite sewer sample and the operability of the monitoring equipment, observed the most current calibration labels on equipment used to collect samples

14 reviewed SOP-40031, Waste Effluent Monitoring and Sampling, Version 18 reviewed records of discharges to the sanitary sewer system for calendar year (CY) 2023-1st quarter. through CY 2025 to verify compliance with 10 CFR 20.2003 limits interviewed the Environmental Manager to verify that site wide enrichment increase modifications will substantially change the PEM processes and challenge the annual sewer effluents limits Radioactive Airborne Effluents (IP Section 02.08)

The inspectors observed operations, reviewed sample collection and analysis procedures, reviewed radiological effluent monitoring reports and monitoring records, and discussed the radioactive airborne effluent results with licensee staff to verify compliance with aspects of 10 CFR 20.1101, 10 CFR 20.2103, and the license application. Specifically, the inspectors completed the following activities:

reviewed E06-05-001, Environmental Standards, Revision 2 reviewed SOP-40032, Radioactive Gaseous Effluent Sampling, Version 31 Effluent Monitoring (IP Section 02.09)

The inspectors observed operations, reviewed IROFS and associated surveillance packages, and discussed the results with the licensee to verify compliance with Subpart H of 10 CFR 70, the license application, and the ISA. Specifically, the inspectors completed the following activities:

reviewed IRMO 2080 IRM for flowmeter calibration records in various locations from September 2024 through February 2025 reviewed surveillance packages for the following IROFS for the Industrial Wastewater Treatment Facility (System 163)

IROFS 2307 (monthly accumulations inspections for TK-717 & 714)

IROFS 2309 (calibration records for gamma monitor)

IROFS 2322 (testing of carbon monitor audible/visual alarm testing)

IROFS 2329 (functional testing of HEPA filter)

IROFS 6225 (IX column pre-filter testing and observation) reviewed procedure SWI-40487 A, Waste Generator Disposal Pathways, Version 9 for updates and/or substantial changes Semiannual Effluent Reports (IP Section 02.10)

The inspectors reviewed the licensees effluent monitoring report to verify compliance with the requirements of 10 CFR 70.59. Specifically, the inspectors completed the following activities:

reviewed semiannual effluent reports for the following reporting periods:

NRC required reporting of Effluents 1st Half 2022 dated 8/31/22 NRC required reporting of Effluents 2nd Half 2022 dated 2/28/23

15 NRC required reporting of Effluents 1st Half 2023 dated 8/31/23 NRC required reporting of Effluents 2nd Half 2023 dated 2/28/24 NRC required reporting of Effluents 1st Half 2024 dated 8/29/24 NRC required reporting of Effluents 2nd Half 2024 dated 2/27/25 discussed usage of CAP88 program with a health physicist reviewed E06-09-017,2024 Annual Groundwater Report, Version 1.0 reviewed technetium sampling semiannual reports Quality Control of Analytical Measurements (IP Section 02.11)

The inspectors observed analytical laboratory operations and reviewed records of sample methods to verify compliance with the quality control requirements in the license application.

Specifically, the inspectors completed the following activities:

reviewed E05-11-001, Quality Assurance/ Management Measures for Richland's radionuclide air emission units observed analysis of daily sewer samples and interviewed staff regarding weekly analysis of composite sewer samples reviewed SOP-41096, Analysis of Ions by Ion Chromatography System (ICS)

Model 1600 observed operation and calibration of ICS 1600 (serial number 15123295) used to analyze fluoride in stack samples and daily sewer samples with an environmental lab technician walked through operation and calibration of Agilent System ID 7700 (serial number 11231115) and discussed use of control standards for calibration and analysis of uranium and technetium-99 in daily and composite sewer sample with an environmental lab technician reviewed the maintenance log for Agilent System ID 7700 reviewed SOP-40560,Evaluation and Reporting Out of Specification Analyses reviewed SOP-40566, Laboratory Data Quality Plan Public Dose Analysis (IP Section 02.12)

The inspectors reviewed dose assessment records and associated reports to verify compliance with 10 CFR 20.1301, 10 CFR 20.1302, and the reporting requirements of 10 CFR 20.2107. Specifically, the inspectors completed the following activities:

reviewed Q1 2025 and Q4 2024 Environmental Dosimetry Results with a health physicist reviewed SOP-40033, Environmental Dosimetry reviewed the Environmental Sample Report for Richland Wastewater Treatment Facility Slides for all quarters of 2024 reviewed background results for four thermoluminescent dosimeters to verify compliance with license requirements reviewed SOP 40042, Routine Fenceline/Building Exterior Radiation Level Surveys, Revision 10

16 reviewed fence line external dose rates from various locations (17) to verify compliance with license commitments Environmental Sampling (IP Section 02.13)

The inspectors reviewed environmental sampling records of surface water, sediment, soil, vegetation, ambient air, groundwater, direct radiation, and/ or sanitary sewer sludge, as applicable, to verify compliance with 10 CFR 20.1501 and the license application.

Specifically, the inspectors completed the following activities:

reviewed E06-09-017, 2024 Annual Groundwater Report reviewed SOP-40034, Environmental Surface Soil Sampling reviewed SOP-40039, Richland WWTF Sludge Sampling and discussed quarterly sample analysis with the lead chemist and the Environmental Manager reviewed record of soil sampling from January 2025 reviewed forage sample analysis from June 2025 Minimizing Facility and Environmental Contamination and Facilitating Decommissioning (IP Section 02.14) reviewed E10-05-002, Plant Decommissioning Records required by 10 CRF 70.25(g)(3) version 5.0 discussed spills/ releases outside of restricted areas and referenced source documents with Environmental Manager reviewed CR 2025-1617 regarding UNB Truck Bay Floor contamination to verify the issue had been appropriately screened per the licensee's CAP Radioactive Waste Classification, Characterization, and Storage (IP Section 02.15)

The inspectors reviewed documentation and records of facility activities and observed posting and labeling of storage areas and containers to verify compliance with the requirements of 10 CFR 61.55 and the license application. Specifically, the inspectors reviewed the following records:

reviewed SWI-40487, A, Waste Generator Disposal Pathways, Version 9.0 walked down the radioactive waste storage areas (Dangerous Waste Storage Facility, Modular Extraction Recovery Facility, the Volume Reduction Facility, and the DCO [dry combustible] Waste Storage Facility) reviewed drawing CSA-607,590, Horn Rapids Rd Site General Arrangement Line 1.2 Uranium Recovery UNH Processing & MURS, Revision 18 reviewed SOP-40386, Special/Mixed/Hazardous/Dangerous Waste Handling and Storage, Version 15

17 reviewed AFM Process Containers 13F Scrap Storage, FRM-30379E-Pre-Startup Condition to add additional shielding to the 13F Building (CR-2025-1112)

Waste Burial (IP Section 02.16)

The inspectors reviewed documentation and records of radioactive waste buried onsite prior to January 1981 to verify compliance with 10 CFR 20.2108, as applicable. Specifically, the inspectors reviewed the following records:

interviewed Framatome personnel regarding buried waste onsite and determined the inspection procedure section did not apply Effluent Treatment (IP Section 02.17)

The inspectors conducted walkdowns and observations and reviewed records of onsite waste treatment facilities and airborne effluent scrubbers and filters to verify compliance with the license application. Specifically, the inspectors completed the following activities:

general walkdown of Wastewater Treatment Facility interviewed the chemical engineer responsible for sand filter systems used to treat wastewater walkdown of the following wastewater treatment IROFS o

IROFS 2307, monthly accumulations inspections for TK-717 & 714 o

IROFS 2309, calibration records for gamma monitor o

IROFS 2322, testing for carbon monitor and audible/visual alarm testing reviewed surveillance packages C080P021 for IROFS 2307; IX Pre-Filter 3-month intervals reviewed surveillance packages C1631102 for IROFS 2307; DETEC Assay TK714 1 month interval reviewed surveillance packages S163P001-0001 for IROFS 2322; CO2 Monitor Alarm 6-month interval reviewed surveillance packages C163P104 for IROFS 2309; IX Feed Interlock checks 6-month interval FACILITY SUPPORT 88072 - Plant Modifications (Triennial)

The inspectors conducted an extensive review into the licensees configuration management system for plant modifications to ensure that safety related systems and components (i.e.,

IROFS or credited safety controls) could adequately perform their intended safety function and that system changes had not adversely impacted plant safety and operability. The inspectors review focused on verifying compliance with the applicable requirements in 10 CFR 70 and the license application, Chapter 11, Management Measures.

Selection of Modifications (IP Section 02.01)

18 The inspection team reviewed licensing documents to discuss plant modifications in risk-significant areas/processes with the licensee. The inspectors selected the following process for an in-depth review of historical modifications.

UO2 Ventilation System ECN 5607 L, Direct Digital Control for Air Balance ECN 5730 L, Modify HVAC Deluge Systems to Improve and Simplify the System ECN 5744, Mount Magnahelic and Valve on Wall near Pressure Switches ECN 5859 L, Heat Recovery Coil is Plugged ECN 6143 L, HVAC Control Upgrade for K23, K30, K31 and K36 ECN 6792 L, Remove HVAC System K23 ECN 7000 L, K32 Exhaust System Sampling Mod ECN 7450C, ADU Line 2 and 3 Powder Prep Removal ECN 8017, Replace K32 Fans ECN 8046C, HEPA Filter Access Improvements ECN 8475, HRR Removal of HVAC Deluge System ECN 8659, UNH Process Off Gas (POG) Filter Housing Replacement/Relocation ECN 8661, K31 Exhaust Fan Replacement ECN 8714, COE Grinder Line Installation - HVAC Reconfigure and Component Replacement ECN 8733, COE - Grinder Line #3 Installation ECN 8816, Install new HVAC Exhaust and Supply Service to Grinder Line #1 AFM Related ECN 9033, AFM - HF Recovery - HF Condenser Equipment Modifications ECN 9082, AFM - Ceramics Bucket Equipment ECN 9062, AFM - Fresh Fuel Download Facility (FFDF) - Fresh Fuel Download Equipment Mods ECN 9068, AFM - UO2 Bundle Storage - Bundle Storage Rack Modifications Design Process Review (IP Section 02.02)

For the selected modifications listed above, the inspectors reviewed the design process to verify the licensee followed the applicable configuration management requirements in the license application and 10 CFR 70. Specifically, the inspectors conducted the inspection activities listed below:

interviewed licensee staff, performed walkdowns, and reviewed configuration management packages and supporting documentation to verify that plant modifications were developed, reviewed, classified, approved, and implemented in accordance with 10 CFR 70.72, and the baseline design criteria of 10 CFR 70.64.

interviewed licensee staff, performed walkdowns, and reviewed configuration management packages and supporting documentation to verify that safety systems and components impacted by the modification, including interactions

19 with other systems, would perform their intended safety function as described in the ISA Summary and safety program documentation.

interviewed licensee staff, performed walkdowns of selected systems, and reviewed documentation to verify the licensee applied management measures to the IROFS affected by the modifications in accordance with 10 CFR 70.62(d).

interviewed licensee staff, performed walkdowns, and reviewed corrective action documents for plant modification issues, including configuration management audits, to verify compliance with the CAP activities described in Chapter 11 of the license application. The scope of the corrective action review included outstanding design and operational issues for the processes selected for in-depth review.

System Condition and Capability Review (IP Section 02.03)

For the selected modifications, the inspectors reviewed the system condition and tested capability to verify they were consistent with the applicable design requirements and licensing basis. Specifically, the inspectors conducted the inspection activities listed below:

interviewed NCS engineers regarding IROFS 4512 and 4513, reviewed work orders, and conducted a plant walkdown to ensure modifications were adequately implemented consistent with the configuration management package interviewed the system engineer, conducted plant walkdowns, and reviewed work orders to verify that administrative controls for IROFS 4520 and 4521 that involve operator action could be accomplished as described in the licensees ISA interviewed system engineers, reviewed P&IDs, and conducted plant walkdowns to verify whether the modifications were adequately implemented consistent with the configuration management package performed walkdowns of the UO2 building and Dry Conversion building to verify the modifications in ECNs 9033, 9082, and 9068 were adequately implemented and consistent with the configuration management package performed a walkdown of the SURF to verify modifications to stainless steel piping were implemented reviewed images and interviewed the AFM project manager and engineers regarding the modifications related to ECN 9062 to verify they were adequately implemented reviewed Part 2 - Chapter 18 - Ventilation Systems (Plantwide) and E04-NCSA-960 to verify consistency conducted interviews, reviewed records, and conducted plant walkdowns to verify management measures were properly implemented to ensure that select IROFS or other safety controls were available and reliable to perform their function when needed Post-Modification Testing (IP Section 02.04)

For the selected modifications, the inspectors interviewed licensee staff and reviewed post-modification testing records to determine whether the plant was in a safe configuration

20 during post-modification testing. The inspectors reviewed the following post-modification tests to determine whether post-modification testing ensured adequate implementation of the design and safety system functionality.

reviewed completed Functional Test records and Post-Modification Testing records (Work Orders) for the following HVAC modifications:

Install New HVAC Exhaust and Supply to Grinder Line #1 (ECN 8816)

Installation of Grinder Line #3 (ECN 8733)

UNH POG Filter Housing Replacement/Relocation (ECN 8659)

Modify HVAC Deluge Systems to Improve and Simplify the System (ECN 5730 L)

HVAC Control Upgrade for K23, K30, K31, and K36 (ECN 6143 L)

Remove HVAC System K23 (ECN 6792 L)

K32 Exhaust System Sampling Mod (ECN 7000 L)

Replace K32 Fans (ECN 8017)

HEPA Filter Access Improvements (ECN 8046C)

COE Grinder Line Installation - HVAC Reconfigure and Component Replacement (ECN 8714)

AFM - HF Condenser Equipment Modifications:

Functional Test Plan: POG Piping Pressure Decay Test C840P002-0003, Monitory Uranium HF 1wk In AFM - Ceramic Bucket Equipment:

C390I013-0002, Weight Scale 6mo In C390I006, Scale DCS Scrap 1y In AFM - FFDF Equipment Mods:

Analysis of Borated Polyethylene FFDF Storage Rack Shielding - Structural Calculations C490I008,Scale 3 WIT-60003 6mo In Documentation Review (IP Section 02.05)

The inspectors reviewed a sample of plant documents impacted by the modifications selected for review to verify the licensee had either updated or was in the process of updating such documents to reflect the modifications in accordance with the license application requirements and 10 CFR 70.72. The inspection sample included:

reviewed the suite of procedures related to modifications, plant configurations, change process, etc.:

MCP-30379 suite reviewed operating procedures related to UO2 Building HVAC modifications:

SOP-40701, Air Balance Operations Audit Procedures, Revision 21 SOP-40821, Instruction Manual HEPA and Pre-Filter Change-Outs, Revision 18 SOP-40803, TS&M General Generic Criticality Safety Required Administrative Controls, Revision 9

21 reviewed training records/qualifications for select licensee personnel involved with the ECNs listed in Section 02.01 above reviewed the 2024 audit of the configuration management program reviewed E04-NCSA-960, HVAC Exhaust Systems, related to UO2 Building HVAC modifications reviewed NCSAs related to AFM modification reviewed applicable sections of the ISA Summary review of drawings including:

EMF-700077, 2.5-Gal Bucket Scale Stand Assembly CSA 611, 960, Ventilation Duct System K31 Flow Diagram CSA-618166-100, OB9 Bundle Storage Rack Shielding CSA-700021, HF Recovery System Primary & Secondary Condensers V-502, 503, 504, & V-510 CSA-700067-002, UO2 Bundle Storage West Storage Rack Neutron Absorber Panel #1 CSA-7000145, Moderated Bucket Storage 4 Row Bookshelf CSA-700120, FFDF Bucket Handling Gravity Conveyor 9339 M04M, Uranium Oxide Facility Airflow and Control Diagram ORR REPORT 07001257/2025007 IP 88020 - Operational Safety The inspectors evaluated selected ECNs for the AFM license amendment to verify compliance with 10 CFR 70.72 as well as Chapter 11, Management Measures, of the facilitys license application, and applicable licensee procedures. The ECNs selected for review are listed below:

ECN 9117, AFM - SURF Modifications Phase 2 Demo ECN 9055, AFM Process Containers - Bucket Overpacks ECN 9085, AFM Filtrate Bay Door Removal ECN 9088, AFM Rod and Bundle Hoods ECN 9135, AFM - MURS Liquid Storage In addition to reviewing the ECNs, the inspectors:

walked down completed bucket overpacks, completed modifications for lifts for the scale and bucket hoods and installation of the bucket storage and cleaning table reviewed standard work instructions and operator aids for MURS liquid storage reviewed drawings and analysis for the above ECNs discussed modifications with engineers reviewed applicable revised accident sequences and IROFS INSPECTION RESULTS No issues were identified.

22 EXIT MEETINGS AND DEBRIEFS The inspectors verified that no proprietary information was retained or documented in this report.

On July 10, July 17 and September 11, 2025, the inspectors presented inspection results to Brian Vance and other members of the licensee staff.

23 DOCUMENTS REVIEWED Inspection Procedure Type Designation Description or Title Revision or Date 88015 Corrective Action Documents 88015 CR 2024-3361, 2024-3536, 2025-0283, 2025-1006, 2025-1192, 2025-

1867, Criticality Safety Related Condition Reports Various 88015 Engineering Evaluations 88015 E04-NCSA-100 ADU Process Off Gas System Version 14 88015 Engineering Evaluations 88015 E04-NCSA-545 Product Development Test Facility Version 4 88015 Engineering Evaluations 88015 E04-NCSA-960 HVAC Exhaust Systems Version 43 88015 Procedures 88015 E04-04-003 Criticality Safety Specialist Training and Qualification Program Version 3 88015 Procedures 88015 E04-06-002 Routine Nuclear Criticality Safety Audits Version 8 88015 Procedures 88015 E04-06-004 Preparation and Review of Nuclear Criticality Safety Documents Version 17 88015 Procedures 88015 E18-01-001 External Reporting of Safety, Environmental, MC&A, Transportation, and Security Related Events or Conditions Version 23 88015 Procedures 88015 MCP-30437 Procedure for Implementing Safety Requirements Version 13 88015 Procedures 88015 SOP-40281 K-32 Process Off gas (POG) Ventilation System Version 13 88015 Procedures 88015 SOP-40803 TS&M General Generic Criticality Safety Required Administrative Controls Version 9 88015 Procedures 88015 SOP-40821 Instruction Manual HEPA and Pre-filter Change-outs Version 18 88015 Self-Assessments 88015 E04-07-202411 NCS Audit/Inspection Report - November 2024 12/11/2024

24 Inspection Procedure Type Designation Description or Title Revision or Date 88015 Self-Assessments 88015 E04-07-202501 NCS Audit/Inspection Report - January 2025 02/11/2025 88015 Self-Assessments 88015 E04-07-202504 NCS Audit/Inspection Report - April 2025 05/09/2025 88015 Self-Assessments 88015 E04-07-202505 NCS Audit/Inspection Report - May 2025 06/09/2025 88015 Work Orders 88015 13261825 C960I013 D/P Switch VAC-17 1YR IN 88015 Work Orders 88015 13648244 C960P026 Duct Inspect 12MO OPCR 03/07/2024 88015 Work Orders 88015 13656023 C100P002 L2 POG Duct 6MO OPCH 05/20/2024 88015 Work Orders 88015 13681229 C100P002 L2 POG Duct 6MO OPCH 12/04/2024 88015 Work Orders 88015 13694714 C100P003 K32 Duct Insp 3MO OPCH 02/27/2025 88015 Work Orders 88015 13697427 C100I001 SWIT PRESS HLS184 L2 3MO IN 03/05/2025 88015 Work Orders 88015 13698107 C100P001 L2 Overflow/Vents 12MO PF 03/14/2025 88015 Work Orders 88015 13701254 C100P003 K32 Duct Insp 3MO OPCH 06/11/2025 88015 Work Orders 88015 13701356 C960P032-0001 Filter Porous 3MO OPCR 05/18/2025 88015 Work Orders 88015 13701407 C960P033-0001 Filter Porous 3MO OPCH 05/02/2025 88020 Calculations 88020 Calculation Number: 9393-SI South Bundle Storage Addition Structural Calculations 6/23/2025 88020 Calibration Records 88020 Scale Calibrations -ALS Scale, Equip. C3601007; 07/2026 88020 Calibration Records 88020 GAD Scale Equip. C3601006 07/2026 88020 Corrective Action Documents CR 2024-3536

25 Inspection Procedure Type Designation Description or Title Revision or Date 88020 88020 Corrective Action Documents 88020 CR 2025-0015 88020 Corrective Action Documents 88020 CR 2025-0596 88020 Corrective Action Documents 88020 CR 2025-0655 88020 Corrective Action Documents 88020 CR 2025-0820 88020 Corrective Action Documents 88020 CR 2025-1022 88020 Corrective Action Documents 88020 CR 2025-2105 88020 Drawings 88020 CSA-611080 ADU Process Uranium Recovery Tk-206, Tk-207 P&ID Revision 021.E 88020 Drawings 88020 CSA-611150 Misc UN Recovery SYS Mop Sinks Process & Inst Diagram Revision 008.C 88020 Drawings 88020 CSA-614931 ADU Area and BLEU 45 Gallon Drum Tumbler Station Revision 0 88020 Drawings 88020 DWG-CSA-607,509 AREVA Site General Arrangement Bleu Pelletizing Powder Prep; Sheet 101 Revision 007 88020 Engineering Changes 88020 ECN-9055 AFM Process Containers - Bucket Overpacks 02/14/2024 88020 Engineering Changes 88020 ECN-9085 AFM Filtrate Bay Door Removal 10/23/2024 88020 Engineering Changes 88020 ECN-9088 AFM Rod and Bundles Hoods 01/21/2025 88020 Engineering Changes 88020 ECN-9117 AFM - SURF Modifications Phase 2 Demo 11/05/2024

26 Inspection Procedure Type Designation Description or Title Revision or Date 88020 Engineering Changes 88020 ECN-9135 AFM - MURS Liquid Storage 05/13/2025 88020 Engineering Changes 88020 ECN-9138 Constellation Crane - South Bundle Storage Addition 09/03/2025 88020 Engineering Evaluations 88020 313385-0007 Packaging Specialties Inc. - Certification of Conformance MIL-DTL-6054G 12/23/2024 88020 Engineering Evaluations 88020 E-04-NCSS-G07 Building and Facilities NCS Design Requirements Including Initial Conditions and Bounding Assumptions Version 15 88020 Engineering Evaluations 88020 E04-NCSA-360 Lube Blend Press Feed Version 19 88020 Engineering Evaluations 88020 E04-NCSA-773 UNH Warehouse (13F)

Version 11 88020 Engineering Evaluations 88020 E04-NCSS-G06 Fire Prevention and Firefighting Version 34 88020 Miscellaneous 88020 JCO 2023-003 ADU Luber Failure 09/12/2023 88020 Miscellaneous 88020 JCO 2024-002 Proportional sampler in ARF was disabled due to malfunction or clog in the system 2/12/2024 88020 Miscellaneous 88020 JCO 2025-002 Phone System Out of Service 03/21/25 88020 Miscellaneous 88020 JCO 2025-004 Bypass heater interlock V3-101 07/24/2025 88020 Miscellaneous 88020 PG000013 Glycol/Water Mix 6Mo AB Revision 1 88020 Miscellaneous 88020 PM:004075 Air Handler K61-1-1 1Yr MW Revision 7 88020 Miscellaneous 88020 PM004076 Fan EXH K62-16-1 6Mo MW Revision 7 88020 Miscellaneous PM004077 FAN EXH K62-16-2 (South) 6Mo MW Revision 5

27 Inspection Procedure Type Designation Description or Title Revision or Date 88020 88020 Miscellaneous 88020 Respirators Issued between 1/1/2025 and 4/30/2025 04/30/2025 88020 Miscellaneous 88020 Test Report 827 Certificate of Conformance - MIL-DTL 6054 G Performance Test Report 12/17/2024 88020 Procedures 88020 AID-40326 A Operator Aid Transfer Grinder Water to Tk-206/207 Version 1.0 88020 Procedures 88020 AID-40326 B Operator Aid Transfer of Line 6 Grinder Water to Tk-206/207 Version 1.0 88020 Procedures 88020 E04-NCSS-G06 Fire Prevention and Firefighting 34 88020 Procedures 88020 MCP -30340 Essential Material Class I: 45 Gallon Powder Containers with Neutron Absorber Inserts Version 10 88020 Procedures 88020 SOP-40486 Richland Operations General Rules Version 42.0 88020 Procedures 88020 SOP-40498 Planar Array Storage of SNM in Sea-Land Containers and Warehouses Revision 8 88020 Procedures 88020 SOP-40701 Air Balance Operations Audit Procedure Revision 22 88020 Procedures 88020 SOP-40821 Instructional Manual HEPA and Pre-filter Change-outs Revision 18 88020 Procedures 88020 SOP-41026 UNB Tank Transfer Revision 8 88020 Procedures 88020 SOP-41145 SURF UNB Processing Revision 4 88020 Procedures 88020 SWI-40274 H Standard Work Instruction Transfer of Non-Chemically Contaminated UO2 and Water to Tanks 206 and 207 Version 1.0 88020 Self-Assessments 88020 13723508 Fire Safety Inspection (1 month) - SAF-FGAS 08/27/2025 88020 Self-Assessments 88020 Order 13723508 Fire Safety Inspection 1 month -Location SAF-FGAS 08/27/2025 88020 Work Orders 13677923 PM 004076 Fan Exh K62-16-1 6MO 10/3/2024

28 Inspection Procedure Type Designation Description or Title Revision or Date 88020 88020 Work Orders 88020 13681241 PM004077 Fan Exh K62-16-2 (South) 6 MO 11/12/2024 88020 Work Orders 88020 13698018 PM004075 Air Handler K61-1-1 1YR 3/15/2025 88020 Work Orders 88020 13699406 PG000013 Glycol/Water Mix 6mo 4/16/2025 88020 Work Orders 88020 13701275 PM004077 Fan Exh K62-16-2 (South) 6MO 5/31/2025 88020 Work Orders 88020 13762807 PG000013 Glycol/ Water Mix 6MO 10/2/2025 88020 Work Orders 88020 C360P003-001 (East)

IROFS 1508 Drum Tumbler Hood Free Draining 05/01/2025 88020 Work Orders 88020 C360P003-002 (West)

IROFS 1508 Drum Tumbler Hood Free Draining 05/1/2025 88020 Work Orders 88020 C360P003-003 Conversion Prep: IROFS 1508 Drum Tumbler Line 6 07/01/2025 88020 Work Orders 88020 C360P004-001 (East)

IROFS 1510 -Drum Tumbler Startup Interlock Switch-Functional Testing 05/01/2025 88020 Work Orders 88020 C360P004-002 (West)

IROFS 1510 -Drum Tumbler Startup Interlock Switch-Functional Testing 05/01/2025 88020 Work Orders 88020 C360P004-003 Moderated Drum Lock Bar Interlock; IROFS 1513 Drum Tumbler Line 6 07/01/2025 88020 Work Orders 88020 C773P001 Moisture Content (IROFS 1403)

Scrap Storage Prot. 6-month IROFS Scale Weight Indicator; Warehouse 13F 05/01/2025 88020 Work Orders 88020 C773P002 Storage Racks WHS 13F 1 Yr 07/28/2025 88020 Work Orders 88020 C773P002-Order: 13677415 Heat Test: IROFS Bldg Un & Service Equipment (IROFS 3710.10) 10/24/2024 88020 Work Orders 88020 Software Work Order PE-905 HF Scrubber Room/ 1st Floor Zone Strobe Alarm 03/31/2025 88045 ALARA Plans 88045 E05-01-026 The ALARA Report January 1, 2023 thru December 31, 2023 07/30/2024

29 Inspection Procedure Type Designation Description or Title Revision or Date 88045 Calibration Records 88045 IRMO 4210 Yokogawa PH Assembly Calibration 10/2024 88045 Calibration Records 88045 IRMO 4300 ISCO 4230 Bubbler Flow Meter Calibration 06/2025 88045 Calibration Records 88045 IRMO4200 Yokogawa PH Assembly Calibration 06/2025 88045 Calibration Records 88045 Order #

13673486 IRMO 2080 Flowmeter 88045 Corrective Action Documents 88045 CR 2023-2277 88045 Corrective Action Documents 88045 CR 2024-2598 88045 Corrective Action Documents 88045 CR 2024-2598-01 88045 Corrective Action Documents 88045 CR 2025-0015 88045 Corrective Action Documents 88045 CR 2025-0061 88045 Corrective Action Documents 88045 CR 2025-0135 88045 Corrective Action Documents 88045 CR 2025-1049 88045 Corrective Action Documents 88045 CR 2025-1112 88045 Corrective Action Documents CR 2025-1763

30 Inspection Procedure Type Designation Description or Title Revision or Date 88045 88045 Corrective Action Documents 88045 CR 2025-1849 88045 Corrective Action Documents 88045 CR 2025-3636 88045 Drawings 88045 CSA-607, 590 General Arrangement Line 1.2 Uranium Recovery UNH Processing & MURS Revision 18 88045 Drawings 88045 CSA-607,590 Horn Rapids Rd Site General Arrangement Line 1.2 Uranium Recovery UNH Processing & MURS Revision 18 88045 Engineering Changes 88045 ECN-9054 AFM Process Containers 13F Scrap Storage, FRM-30379E-Pre-Startup Condition to add additional shielding to the 13F Bldg.

05/13/2025 88045 Engineering Evaluations 88045 E05-11-001 Quality Assurance/ Management Measures for Richland's Radionuclide Air Emission Units Version 6.0 88045 Engineering Evaluations 88045 E10-05-002 Plant Decommissioning Records required by 10 CRF 70.25(g)(3)

Version 5.0 88045 Miscellaneous 88045 Semiannual technitium report Various 88045 Miscellaneous 88045 Various training and qualification records 88045 Miscellaneous 88045 EHS&L Environmental Health, Safety and Licensing Audit/Inspection Schedule 7/17/25 88045 Miscellaneous 88045 Semiannual Effluent Reports Required Reporting of Effluents per 10 CFR 70.59 various 88045 Procedures 88045 1703-88 US Fuel CAP (DevonWay iCap)

Rev. 07 88045 Procedures 88045 1703-88-F02 Condition Report-Component Nonconformance 00 88045 Procedures 88045 1703-88-F03 Condition Report: EHS&L Condition 00

31 Inspection Procedure Type Designation Description or Title Revision or Date 88045 Procedures 88045 E06-05-001 Environmental Standards Version 2.0 88045 Procedures 88045 E10-05-002 Plant Decommissioning Records by 10 CFR 70.25 (g)(3)

Version 5.0 88045 Procedures 88045 E12-03-042 Environmental Surveillance Version 3.0 88045 Procedures 88045 SOP-40791 Pre-Job Briefing Procedure Version 21.0 88045 Procedures 88045 SOP-40031 Waste Effluent Monitoring and Sampling Version 20.0 88045 Procedures 88045 SOP-40032 Radioactive Gaseous Effluent Sampling Version 31.0 88045 Procedures 88045 SOP-40033 Environmental Dosimetry Version 14.0 88045 Procedures 88045 SOP-40039 Richland WWTF Sludge Sampling Version 10.0 88045 Procedures 88045 SOP-40042 Routine Fenceline/Building Exterior Radiation Level Surveys Version 10.0 88045 Procedures 88045 SOP-40174 General Facility Radiation Work Procedure Version 35.0 88045 Procedures 88045 SOP-40386 Special/Mixed/Hazardous/Dangerous Waste Handling and Storage Version 15 88045 Procedures 88045 SOP-40560 Evaluation and Reporting Out of Specification Analyses Version 10.0 88045 Procedures 88045 SOP-40566 Laboratory Data Quality Plan Version 16.0 88045 Procedures 88045 SOP-41159 HST Incident Response Version 5.0 88045 Procedures 88045 SWI-40487 A Waste Generator Disposal Pathways Version 9.0 88045 Self-Assessments 88045 BSK:24:001 Annual Radioactive Waste Handling Audit 04/25/2024 88045 Self-Assessments 88045 E06-09-017 2024 Annual Groundwater Report Version 1.0

32 Inspection Procedure Type Designation Description or Title Revision or Date 88045 Work Orders 88045 C080P021 IX Pre-Filter 3 months (IROFS Filter IX Columns) 03/01/2025 88045 Work Orders 88045 C080P024 IX Pre-Filter 3 months-IROFS UF6 Line2 Waste Ion Exchange System 01/28/2025 88045 Work Orders 88045 C1631102-0001 DETEC Assay TK714 1 month-IROFS Detector Assay TK714 05/04/2025 88045 Work Orders 88045 C163P101 PH Adjustment TK-717 1 month 05/14/2025 88045 Work Orders 88045 C163P104 IX Feed Interlock Checks 6 months= IROFS Ammonia Recovery System 01/12/2025 88045 Work Orders 88045 C163P104 IX Feed Interlock Checks 6 months - IROFS Ammonia Recovery System 07/25/2024 88045 Work Orders 88045 C163P106 IX Feed TK-714 - Various Surveillances 04/18/2025 88072 Drawings 88072 3959-K-006 HVAC K1 & K2 SUPPLY DUCT PLAN 88072 Drawings 88072 3959-K-007 HVAC K3 EXHAUST SYSTEM 31, XA, XB, XC 88072 Drawings 88072 3959-K-58 K30 & K31 SUPPLY & EXHAUST FIRST FLOOR PLAN &

DETAIL 11 88072 Drawings 88072 3959-K-61 UF6 NO 3 EXPANSION ROOF PLAN & DETAILS SUPPLY &

EXHAUST 7

88072 Drawings 88072 3959-K-71 HVAC K38 SUPPLY SYSTEM PARTIAL ROOF PLAN AND SECTIONS 6

88072 Drawings 88072 602-000 sheet 2 K3 and K9 Exhaust Fan Systems-Uranium Oxide Building Revision 07 88072 Drawings 88072 9339 M04M Uranium Oxide Facility Airflow and Control Diagram Revision 13 88072 Drawings 88072 CSA-607,590 HORN RAPIDS RD SITE GENERAL ARRANGEMENT XB 88072 Drawings 88072 CSA-607590 Horn Rapids RD Site General Arrangement 88072 Drawings 88072 CSA-611, 100 K32 LINE 2 PROCESS OFF GAS P & ID 13 88072 Drawings 88072 CSA-611, 190 PELLET DISSOLVER P & ID 4

88072 Drawings 88072 CSA-611, 960 VENTILATION DUCT SYSTEM K31 FLOW DIAGRAM (sheet 12) 0 88072 Drawings 88072 CSA-612303 HF Recovery System Primary Condensers 88072 Drawings 88072 CSA-614937 Facilities Waste and Storage Gid Locations 88072 Drawings 88072 CSA-618166-100 OB9 Bundle Storage Rack Shielding

33 Inspection Procedure Type Designation Description or Title Revision or Date 88072 Drawings 88072 CSA-700021 HF Recovery System Primary & Secondary Condensers V-502, 503, 504, & 510 88072 Drawings 88072 CSA-700066 UO2 Bundle Storage Structural Rack Elevations 88072 Drawings 88072 CSA-700067-002 UO2 Bundle Storage West Storage Rack Neutron Absorber Panel #1 88072 Drawings 88072 CSA-700120 FFDF Bucket Handling Gravity Conveyor 88072 Drawings 88072 CSA-700144 Moderated Bucket Storage 4 Row Bookshelf 88072 Drawings 88072 CSA-700145 Moderated Bucket Storage 3 Row Bookshelf 88072 Drawings 88072 DS-GF-021-06 PLAN VIEW 13 88072 Drawings 88072 DS-GF-045-99 DUCT PROBE INSTALLATION 88072 Drawings 88072 DS-ML-019-14 LINE 3 PELLET GRINDING AND INSPECTION ELECGTRICAL DIST'N X

88072 Drawings 88072 EMF-602,683 ELECTRICAL ONE-LINE DIAGRAM DISTRIBUTION PANEL

'B-1' X

88072 Drawings 88072 EMF-607985 Exhaust Air Systems Deluge Drains Modifications Site Plan 88072 Drawings 88072 EMF-608, 178 NAF SINTERING PELLET SYSTEM SECOND FLOOR PLANS 3

88072 Drawings 88072 EMF-609, 898 NORTH CHILLER REPLACEMENT P&ID UO2 BUILDING 2

88072 Drawings 88072 EMF-610, 810 S ROOM 100 HEPA FILTER PLATFORM FRAMING PLANS AND SECTIONS 0

88072 Drawings 88072 EMF-616782-008 FFDF Storage Rack Shielding Structural Design 88072 Drawings 88072 EMF-700077 2.5-Gal Bucket Scale Stand Assembly 88072 Drawings 88072 EMF-700091 Ceramics Hood Bucket Lift 1 88072 Engineering Changes 88072 ECN-6143 L HVAC Control Upgrade for K23, K30, K31 and K36 04/16/1997 88072 Engineering Changes 88072 ECN-6792 L Remove HVAC System K23 03/01/1999 88072 Engineering Changes 88072 ECN-7000L K32 Exhaust System Sampling Mod 12/14/1999 88072 Engineering Changes 88072 ECN-7450C ADU Line 2 and 3 Powder Prep Removal 04/17/2002 88072 Engineering Changes 88072 ECN-8017 Replace K32 Fans 07/13/2005 88072 Engineering ECN-8046C HEPA Filter Access Improvements 05/25/2006

34 Inspection Procedure Type Designation Description or Title Revision or Date Changes 88072 88072 Engineering Changes 88072 ECN-8475 HRR Removal of HVAC Deluge Systems 02/12/2013 88072 Engineering Changes 88072 ECN-8714 COE Grinder Line Installation - HVAC Reconfigure and Component Replacement 05/30/2014 88072 Engineering Changes 88072 ECN-9033 AFM - HF Recovery - HF Condenser Equipment Modifications 01/24/2025 88072 Engineering Changes 88072 ECN-9062 AFM - FFDF - Fresh Fuel Download Equipment Mods 06/27/2024 88072 Engineering Changes 88072 ECN-9068 AFM - UO2 Bundle Storage - Bundle Storage Rack Modifications 07/12/2024 88072 Engineering Changes 88072 ECN-9082 AFM - Ceramic Bucket Equipment 04/10/2024 88072 Engineering Evaluations 88072 E04-NCSA-370 UO2 Pellet Pressing Version 20 88072 Engineering Evaluations 88072 E04-NCSA-380 Pellet Sintering Area Version 12 88072 Engineering Evaluations 88072 E04-NCSA-390 UO2 Pellet Grinding & Inspection Version 25 88072 Engineering Evaluations 88072 E04-NCSA-490 Rod and Pellet Vault Downloading Version 18 88072 Engineering Evaluations 88072 E04-NCSA-540 Bundle Assembly & Storage Version 21 88072 Engineering Evaluations 88072 E04-NCSA-840 Dry Conversion Liquid Effluent & HF Recovery Version 10 88072 Engineering Evaluations 88072 E04-NCSS-G10 Neutron Absorbers Version 1.0

35 Inspection Procedure Type Designation Description or Title Revision or Date 88072 Miscellaneous 88072 Organizational Chart Fuel - Fuel Operations - Plant Engineering, Technical Support & Maintenance 01/24/2025 88072 Procedures 88072 AID-30379 A Technical Design Bases and Criteria Version 3.0 88072 Procedures 88072 AID-30379 B Project Design Version 4.0 88072 Procedures 88072 AID-30379 C Project Risk Assessments Version 3.0 88072 Procedures 88072 AID-30379 D Test Procedure and Document Review Version 5.0 88072 Procedures 88072 AID-30379 E Design Reviews Version 3.0 88072 Procedures 88072 MCP-30131 Safety/Licensing Evaluation of Facility Changes Version 14.0 88072 Procedures 88072 MCP-30379 Construction or Modification Change Control Version 20.0 88072 Procedures 88072 MCP-30379 A Construction or Modification Change Control - Initiation Version 7.0 88072 Procedures 88072 MCP-30379 B Construction or Modification Change Control - Planning Version 5.0 88072 Procedures 88072 MCP-30379 C Construction or Modification Change Control - Execution Version 14.0 88072 Procedures 88072 MCP-30379 D Construction or Modification Change Control - Controlling Version 9.0 88072 Procedures 88072 MCP-30379 E Construction or Modification Change Control - Closure Version 6.0 88072 Procedures 88072 MCP-30489 HVAC System (System 960) Controls Design Description Version 13.0 88072 Procedures 88072 MCP-31359 Grinder Line 6 (System 390) Controls Design Description Version 4.0 88072 Procedures 88072 SOP-40701 Air Balance Operations Audit Procedures Revision 21 88072 Procedures 88072 SOP-40803 TS&M General Generic Criticality Safety Required Administrative Controls Revision 9

36 Inspection Procedure Type Designation Description or Title Revision or Date 88072 Procedures 88072 SOP-40821 Instruction Manual HEPA and Pre-Filter Change-Outs Revision 18 88072 Self-Assessments 88072 E25-04-2024 2024 Configuration Management Audit 12/17/2024 88072 Work Orders 88072 WO 13261825 C960I013 D/P Switch VAC-17 1YR IN 08/03/2015 88072 Work Orders 88072 WO 13261884 C960I011 D/P Switch VAC-14 1YR IN 08/03/2015 88072 Work Orders 88072 WO 13261885 C960I015 D/P Switch VAC-22 1YR IN 08/05/2016 88072 Work Orders 88072 WO 13261893 C960I012 D/P Switch VAC-15 1YR IN 08/03/2015 88072 Work Orders 88072 WO 13261898 C960I010 D/P Switch VAC-12 1YR IN 08/03/2015 88072 Work Orders 88072 WO 13261900 C960I009 D/P Switch VAC-7 1 YR IN 08/03/2015 88072 Work Orders 88072 WO 13344965 C960I001 Magnahelic D/P Gauge 1Y Calib In 08/03/2017 88072 Work Orders 88072 WO 13650518 CP830P001-0001 PWDR PREP INTRLKS 6MO 05/09/2024 88072 Work Orders 88072 WO 13660042 CP830P001-0003 PWDR PREP INTRLKS 6MO 07/24/2024 88072 Work Orders 88072 WO 13660096 CP830P001-0004 PWDR PREP INTRLKS 6MO 08/02/2024 88072 Work Orders 88072 WO 13668847 C960I010 D/P Switch VAC-12 1YR IN 08/20/2024 88072 Work Orders 88072 WO 13668948 C960I009 D/P SWITCH VAC-7 1YR IN 08/02/2024 88072 Work Orders 88072 WO 13677982 C830P001-0001 PWDR PREP INTRLKS 6MO 10/28/2024 88072 Work Orders 88072 WO 13686710 C830P001-0003 PWDR PREP INTRLKS 6MO 02/20/2025 88072 Work Orders 88072 WO 13686753 C830P001-0004 PWDR PREP INTRLKS 6MO 01/09/2025

37 Inspection Procedure Type Designation Description or Title Revision or Date 88072 Work Orders 88072 WO 13699471 C830P001-0001 PWDR PREP INTRLKS 6MO 04/23/2025 88072 Work Orders 88072 WO 13719366 DOS Test Exhaust Final Filter 24 MO 06/25/2025