ML26021A097

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Global Nuclear Fuel - Americas Integrated Inspection Report 07001113/2025004
ML26021A097
Person / Time
Site: 07001113
Issue date: 01/21/2026
From: Nicholas Peterka
NRC/RGN-II/DFRSS/FOB1
To: Suits B
Global Nuclear Fuel
References
IR 2025004
Download: ML26021A097 (0)


Text

Brett Suits Facility Manager Global Nuclear Fuel - Americas, LLC.

PO Box 780, Mail Code J20 Wilmington, NC 28401

SUBJECT:

GLOBAL NUCLEAR FUEL - AMERICAS - INTEGRATED INSPECTION REPORT 07001113/2025004

Dear Brett Suits:

On December 31, 2025, the U.S. Nuclear Regulatory Commission (NRC) completed inspections at Global Nuclear Fuel - Americas and Global Laser Enrichment and discussed the results of these inspections with members of your staff. The results of these inspections 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 and make progress on other high-priority activities associated with the ADVANCE Act and Executive Order 14300. 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 NRC modified the facilitys inspection plan (ML25344A465) considering inspection of partial samples, previously inspected, and deferred inspections in accordance with IMC 2600.

January 21, 2026

2 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, Nicholas E. Peterka, Acting Chief Fuels Oversight Branch 1 Division of Fuels, Radiological Safety, and Security Docket No. 07001113 License No. SNM-1097

Enclosure:

As stated cc w/ encl: Distribution via LISTSERV Signed by Peterka, Nicholas on 01/21/26

ML26021A097 X

SUNSI Review X

Non-Sensitive

Sensitive X

Publicly Available

Non-Publicly Available OFFICE RII/DFRSS RII/DFRSS NAME L. Pitts N. Peterka DATE 1/21/2026 1/21/2026

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

07001113 License Number:

SNM-1097 Report Number:

07001113/2025004 Enterprise Identifier:

I-2025-004-0036 Licensee:

Global Nuclear Fuel - Americas, LLC.

Facility:

Global Nuclear Fuel - Americas and Global Laser Enrichment Location:

Wilmington, NC Inspection Dates:

October 27, 2025 to December 12, 2025 Inspectors:

M. Day, Fuel Facilities Inspector L. Pitts, Sr. Fuel Facility Project Inspector T. Sippel, Sr. Fuel Facility Project Inspector P. Startz, Fuel Facilities Inspector K. Sullivan, Fuel Facilities Inspector Approved By:

Nicholas E. Peterka, Acting Chief Fuels Oversight Branch 1 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 at Global Nuclear Fuel - Americas (GNFA) and Global Laser Enrichment (GLE), 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 INSPECTION SCOPES Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Inspections were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2600, Fuel Cycle Facility Operational Safety and Safeguards Inspection Program. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

SAFETY OPERATIONS 88020 - Operational Safety The inspectors evaluated selected aspects of the licensees Operational Safety program to verify compliance with selected portions of Title 10 of the Code of Federal Regulations Part 70 (10 CFR 70), including 70.24, 70.61, 70.62, and Chapter 11, Management Measures, of the facilitys license application, and applicable licensee procedures. Two separate operational safety inspections (one at GNFA and one at GLE) were performed and are documented below.

GNFA and GLE are separate facilities but operate under the same NRC license.

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

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

Node 704, Incinerator o

Accident Sequence 5.21.2.1 - Moderator Enters Incinerator with Excessive Uranium Accumulation Node 706, Pads o

no credible accident sequences with hazards of concern were identified in the What-If Analysis in Process Hazards Analysis (PHA)-706-704, "ISA Reference Report for the 706-704 Node Group," Revision (Rev.) 11, for the pads Node 803/804, Heating, Ventilation, and Air Conditioning (HVAC) o Accident Sequence 5.23.2.1 - High Concentration of Uranium Hexafluoride (UF6)/Hydrogen Fluoride (HF) in Scrubber Outlet Air o

Accident Sequence 5.23.2.2 - Uranium Accumulates in Primary High Efficiency Particulate Air (HEPA) System (Dry Uranium Dioxide (UO2) Applications) o Accident Sequence 5.23.2.3 - Moderator Leaks onto Primary HEPA System (Dry Triuranium Octoxide (U3O8) Application) o Accident Sequence 5.23.2.4 - Moderator Leaks on Primary HEPA System (Moderator Restricted Area Applications)

4 o

Accident Sequence 5.23.2.5 - Uranium Accumulates in Primary HEPA System (Wet Uranium Oxide (UOx) Applications) o Accident Sequence 5.23.2.6 - Uranium Accumulates in Primary HEPA Ductworks (Wet UOx Applications) o Accident Sequence 5.23.2.7 - Uranium Accumulates in Secondary HEPA Filter Systems o

Accident Sequence 5.23.2.8 - Uranium Accumulates in the Scrubber o

Accident Sequence 5.23.2.9 - High Concentration of Uranium in Building Exhaust The inspectors reviewed the accident sequences associated with GLE and conducted a general plant tour of each major plant operating area. The accident sequences selected for review at GLE are listed below:

TL-R-01e - UF6 Release to Gas Handling System (GHS) Room - Collector Module (CM)

Failure Due to Crane Activities TL-R-01f - UF6 Release to GHS Room - CM Failure Due to Dewar Drop TL-R-01g - UF6 Release to GHS Room - CM Failure by High Pressure TL-R UF6 Release to GHS Room - CM by Uncontrolled Heating of a UF6 Plug TL-R UF6 Release to GHS Room - GHS Breach due to Crane Activities TL-R UF6 Release to GHS Room - GHS Failure by Uncontrolled Heating of a UF6 Plug TL-R UF6 Release to GHS Room - UF6 Reservoir Failure by High Pressure TL-R UF6 Release to GHS Room - Failure by High Pressure TL-R UF6 Release to GHS Room - GHS Breach due to Missile Impact TL-R UF6 Release to GHS Room - CM Breach due to Missile Impact TL-R UF6 Release to GHS Room - Failure by High Pressure TL-C Criticality in the GHS due to High Enrichment in the UF6 Feed TL-C Criticality in the GHS due to Loss of Mass Control - UF6 Overfill of the UF6 Reservoir TL-C Criticality in the GHS due to Internal/External Moderation Leak TL-F Fire Adjacent to GHS Room or Maintenance Room TL-F Transient Combustible Fire Internal to GHS Room or Maintenance Room TL-F Fixed Fire Internal to the GHS Room TL-F UF6 Release to GHS Room - Flammable Gas Detonation or Deflagration Inside Raman Cell TL-F UF6 Release to GHS Room - Large Transient Fire in Laser Room Exposing Raman Cell TL-F UF6 Release to GHS Room - Hydrogen Detonation or Deflagration During Raman Cell Loading TL-F UF6 Release to GHS Room - Hydrogen Detonation or Deflagration During Raman Cell Venting TL-F UF6 Release to GHS Room - Flammable Gas Detonation Outside Raman Cell Review of Safety Controls and Related Programs (IP Section 02.02)

The inspectors reviewed information related to administrative and engineered safety controls or items relied on for safety (IROFS) for the accident sequences selected above, including the identification of the licensees assumptions and bounding cases as they apply to each of the selected accident sequences, safety controls, or IROFS. This review was performed

5 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 IROFS selected for review at GNFA are listed below:

Node 704, Incinerator o

IROFS 704-08, Incinerator Moderation Controls - Passive Engineered Control (PEC) o IROFS 704-09, Incinerator Mass Controls - Administrative Control (AC)

Node 706, Pads o

NA (IROFS are applied upstream)

Node 803/804, HVAC o

IROFS 803-01, Primary HEPA Filter Monitoring - AC o

IROFS 803-02, Process Equipment Barrier - Primary HEPA Housing and Ductwork - PEC o

IROFS 803-03, HVAC Duct Design and Holdup Monitoring - AC o

IROFS 803-04, Primary HEPA Filter - Safe Geometry - PEC o

IROFS 803-05, Primary HEPA Filtration - AC o

IROFS 803-06, Secondary HEPA Filter Monitoring - AC o

IROFS 803-07, Grinder Apitron Filters - AC o

IROFS 803-08, Dry Scrap Recycle (DSR) Baghouse Filters - AC o

IROFS 803-09, Secondary HEPA Filtration - AC o

IROFS 803-10, Ductwork Inspection and Cleanout - AC The inspectors also walked down selected areas, including the pads, decontamination area, and the incinerator building, to verify that there were no accumulations of combustible material in excess of licensee procedural requirements.

The IROFS selected for review at GLE are listed below:

TL-CS Mass Control 1: Engineering Process Scale Delta Weight Measurement - AC TL-CS Mass Control 2: Operations Accountability Scale Delta Weight Measurement

- AC TL-HF-03CG - Rupture Disk on the Carrier Gas Supply Line - PEC TL-HF-03PG - Rupture Disk for the Main Vacuum Vessel - PEC TL-HF-04a - Sense and Flee - HF - AC TL-HF-04c - Sense and Flee - Fire - AC TL-HF Crane Lift Control Process - AC TL-HF Combustible Control - AC TL-HF Protective Cover on the Collector Module - PEC TL-HF Plug Removal Process - AC TL-HF Radiant Shield - PEC TL-HF 12B Cylinder Storage Requirements - AC TL-HF Pressurized Gas Cylinder Handling and Storage - AC TL-HF-117 - UF6 Reservoir Pressure Relief System - PEC TL-HF-119 - THEC/PHEC Pressure Relief System - PEC TL-HF-122 - Collection Vessels Pressure Relief System - PEC TL-RC Laser Room Blast Protection - PEC TL-RC Laser Room Blast Resistant Personnel Access/Egress Door - PEC TL-HF-200 - Use of Appropriate PPE - AC

6 TL-HF-201 - HF Exposure Treatment - Dermal and Ocular - AC Implementation of Safety Controls (IP Section 02.03)

For the selected safety controls listed above, the inspectors reviewed selected 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 at GNFA to verify the implementation of selected safety controls:

walked down the incinerator and interviewed an operator, the area engineer, and NCS engineers walked down the pads with area personnel walked down a sample of primary HEPA filter units, secondary HEPA filter units, and Apitron filter units, including the instruments used to monitor them interviewed HVAC technicians and reviewed daily log sheets of checks on differential pressure gauges that implement IROFS 803-01 interviewed HVAC technicians about the periodic preventative maintenance performed on the IROFS differential pressure gauges and observed HVAC technicians simulate the preventative maintenance, including use of a calibrated instrument to verify differential pressure gauges are reading correctly reviewed purchase order for IROFS HEPA filters to verify that design requirements were implemented by incorporation into the purchase order for IROFS 803-05, and -09 reviewed portions of OP 1240.00.205 that implement IROFS 803-08 reviewed OP 1080.00, related to incinerator operations reviewed portions of the OP 1081.01 series of procedures, that implement IROFS 704-08 and -09 reviewed portions of the OP 2301.00 series of procedures, that implement IROFS 803-01, -02, -04, -05, -07, -09, -10 interviewed licensee engineers and reviewed assumptions for noncredible accident sequences (e.g., scrubber water backflowing into the incinerator) applicable to the incinerator The inspectors conducted the following activities to verify the implementation of selected GLE safety controls:

performed walkdowns to verify implementation of the IROFS that are listed in section 02.02 above interviewed licensee staff regarding performance of inspections associated with IROFS TL-HF-06 interviewed licensee staff regarding performance of IROFS TL-CS-01 and TL-CS-02 interviewed licensee staff assigned to perform inspections to verify they were knowledgeable of the requirements associated with their assigned inspections 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

7 CFR 70 and applicable sections of the license application. Specifically, the inspectors conducted the following activities at GNFA:

reviewed Work Order (WO) 5437151, which is associated with the DSR Baghouse and IROFS 803-08 reviewed GNFA Radiation Survey Report, "Incinerator Overhead Pipe Survey," dated March 27, 2024 for IROFS 704-09 reviewed a sample of Incinerator Ash and Incinerator Scrubber Cleanout sample results for IROFS 704-09 interviewed NCS engineer about HEPA filter mass accumulation records and control of the frequency of filter change outs interviewed HVAC technicians about non-IROFS differential pressure monitoring devices and alarms reviewed "3Q2025 Nuclear Safety Audit - Decon, Incinerator Building, Outside Storage Pads," dated September 30, 2025 reviewed "3Q2025 Nuclear Safety Audit - HVAC Systems - Nodes 803 and 804," dated September 26, 2025 interviewed the incinerator area engineer, and an operator assigned to the incinerator, about incinerator controls, upsets, recent operational changes and normal operations reviewed IROFS training documents (TDs) for selected IROFS in Nodes 704, 803, and 804 reviewed IROFS failure and degradation records and trend analysis for 2018 to 2025 reviewed corrective action program (CAP) entries and associated documents related to operational safety, including CAP entries opened as a result of licensee audits and self-assessments reviewed Safety Assessment for Condition Report (CR) 49762 reviewed Safety Assessment for CR 49357 The inspectors conducted the following activities at GLE:

observed signage and boundaries related to control of the radiant shield, and combustible controls interviewed licensee staff regarding control of lifting equipment in the area of the CM FACILITY SUPPORT 88051 - Evaluation of Exercises and Drills The inspectors were unable to conduct an onsite inspection of the GNFA emergency exercise due to the government shutdown, therefore, after the exercise, NRC inspectors reviewed documents related to the licensees graded biennial exercise conducted on October 29, 2025, involving both on-site and off-site participants, to verify compliance with 10 CFR 70.32(i), the Emergency Plan, and Chapter 7, "Fire Safety" of the license application. The scenario included a fire that developed on a pellet press that was processing uranium powder, loss of control of the uranium powder feed hopper, and personnel injuries with potential radiological contamination.

8 Exercise Planning (IP Section 02.01)

The inspectors reviewed the emergency exercise documentation to verify compliance with the Emergency Plan, Emergency Plan Implementing Procedures and 10 CFR 70.32(i). Specifically, the inspectors performed the following activity:

reviewed the GNFA 2025 Biennial Evaluated Exercise 60-day NRC Submittal Scenario, to verify that:

o the emergency exercise scenario tested all elements of the Emergency Plan o

the emergency exercise scenario was based on scenarios that were identified as credible or probable for the facility o

exercise personnel, including controllers and players, were briefed on their duties and responsibilities prior to the exercise Exercise Execution and Emergency Plan Implementation (IP Section 02.02)

The inspectors reviewed the Emergency Organization Evaluated Exercise Controller and Evaluation Brief, Exercise Roster, Controller Critique Roster, Player Brief Roster, 2025 NRC Evaluated Exercise 10-25-2025 Final Package with attachments, and the GNFA RADIOLOGICAL CONTINGENCY AND EMERGENCY PLAN (RC&EP), Revision 43 to verify compliance with the Emergency Plan, Emergency Plan Implementing Procedure, and 10 CFR 70.32(i). Specifically, the inspectors reviewed documented evidence of:

the licensees assessment and classification of the exercise scenario emergency operations center (EOC) staffing offsite response organizations' participation drafting of timely offsite notifications response to emerging situations to address the exercise scenario and meet the exercise objectives press release approval and issuance the emergency response teams actions including securing the scene of the incident Critiques, Exercise Control, and Identification and Resolution of Problems (IP Section 02.03)

The inspectors reviewed the licensees post-exercise lessons-learned meetings, meeting attendance records, and evaluation of issues considered for entry into the CAP to verify compliance with the Emergency Plan, Emergency Plan Implementing Procedure, and 10 CFR 70.32(i). Specifically, the inspectors conducted the following activities:

reviewed the documentation of comments and suggestions for improvement by licensee evaluators in the GNFA Emergency Preparedness Exercise Report critiques verified drill and exercise improvement opportunities are communicated to the emergency organization in the annual requalification training verified opportunities to improve are a part of all drills/exercises reviewed the objectives indicating that no identified issue rose to the level of a CAP issue

9 88070 - Permanent Plant Modifications The inspectors conducted a review to verify the licensee had established and implemented a configuration management system to evaluate, implement, and track changes to the facility in accordance with the applicable requirements in 10 CFR 70.72 and the License Application, Chapter 11, Management Measures. The inspectors review also verified the licensee had established management measures for changes to the facility in accordance with 10 CFR 70, Subpart H and the License Application, and that modifications involving new processes met the requirements in 10 CFR 70.64.

Sample Selection (IP Section 02.01)

The inspectors reviewed licensing documents, changes the licensee determined did not require pre-NRC approval under 10 CFR 70.72, and changes that affected the ISA summary to select changes/modifications to review. To assess whether the licensee conducted evaluations according to their established configuration management system, the inspectors selected the following plant modifications, identified as electronic Change Requests (eCR), and CRs related to configuration management to review:

eCR-52471 "ISA Document Update for Direct Oxidation (DO) Furnace Addition" eCR - 52425 "DO Furnace Installation and Operation" eCR - 51761 "Swarf Press Removal" eCR - 52225 "Revise the Safety Function of IROFS 405-03/ 504-03" CRs 44361, 49263, 49534, 49540, 50366 Facility Change/Modification Process (IP Section 02.02)

The inspectors reviewed the selected modifications listed above to verify the licensee established a configuration management system in accordance with 10 CFR 70.72 and the conditions of the license. Specifically, the inspectors conducted the following activities:

interviewed licensee staff and performed walk downs of the swarf press that is now out of commission per eCR-51761 and the UO2 and gadolinium (GAD) sintering furnace pellet boat transfer carts which had IROFS modifications per eCR-52225 reviewed the following procedures to verify the configuration management system was documented in written procedures and the procedures addressed the aspects in 10CFR70.72(a):

o WI-16-106-02, Revision 23 o

WI-16-106-01, Revision 5 o

CP-16-106, Revision 13 o

WI-27-106-14, Revision 4 o

WI-06-100-26, Revision 5 reviewed licensee's ISA summary submitted 1/30/2025 to verify the licensee submitted a summary with facility changes and revised ISA summary pages to NRC in accordance with 10 CFR 70.72(d)

Management Measures (IP Section 02.03)

For the selected modifications, the inspectors reviewed the management measures established for affected IROFS (or credited safety controls) to verify the management measures ensured the

10 IROFS (or credited safety controls) were available and reliable to perform their intended function as required by 10 CFR 70.61 and the license. Specifically, the inspectors conducted the following activities:

interviewed licensee staff and reviewed change management procedures to verify the licensee implemented the aspects described in configuration management system procedures and section 11.2 of the license application reviewed CAP entries to determine whether the licensee identified configuration management issues and corrected the conditions reviewed Temporary Facility Change (TFC) 50753 and associated Temporary Operating Procedures (TOPs) to verify the licensee implemented TOPs in compliance with plant procedures interviewed licensee operators to verify that procedural changes done as part of eCR packages were trained on prior to implementation interviewed licensee staff to verify audits were being conducted in accordance with the license application section 11.2.5 and facility procedures (WI-18-104-

02) reviewed recent audits including:

o Nuclear Quality Assurance (NQA) -2025-05 o

NQA-2024-03 License Application Changes (IP Section 02.04)

For the selected modifications, the inspectors interviewed licensee staff and reviewed applicable sections of the license application to verify the licensee evaluated license application changes and conducted NRC pre-approval screenings in accordance with the license requirements.

Specifically, the inspectors conducted the following activities:

reviewed the licensee's procedure WI-16-106-02 and the form WI-16-106 F used to determine whether NRC pre-approval of license application changes is required to verify that the licensee's process for evaluating license application changes was in accordance with the license and regulatory requirements reviewed change evaluations documented in ISA Reviewer Change Evaluation Forms associated with the selected change requests listed below to verify the licensee maintained records of the evaluations and provided the bases for determining the change did not require prior NRC approval:

o eCR - 52265 "Modification of requirements for IROFS 101 UF6 Cylinder Skin Temperature" o

eCR-52471 "ISA Document Update for DO Furnace Addition" o

eCR - 52425 "DO Furnace Installation and Operation" o

eCR - 51761 "Swarf Press Removal" o

eCR - 52225 "Revise the Safety Function of IROFS 405-03/ 504-03" interviewed the Configuration Management Controllers and discussed tracking of facility changes through the Excellence Through Quality (ETQ) system, including how changes get assigned to proper area managers and the ISA reviewers as needed

11 New Processes at Existing Facilities (IP Section 02.05)

The inspectors reviewed the eCR of the new facility processes to verify the licensee addressed the requirements of 10 CFR 70.64 and evaluated whether prior NRC approval was needed for the change in accordance with 10 CFR 70.72 and the license conditions. Specifically, the inspectors conducted the following activities:

Records Retention (IP Section 02.06)

The inspectors reviewed a sample of plant documents impacted by the selected modifications to verify the licensee maintained records of facility changes in accordance with the license requirements and 10 CFR 70.72. The sample of documents included:

INSPECTION RESULTS No violations of more than minor significance were identified.

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

On December 11, 2025, the inspectors presented the GLE operational safety inspection results to Phillip Jacobs and other members of the licensee staff.

interviewed licensee staff and performed walk downs of the DO furnace reviewed Fire Hazard Analysis (FHA) 1001.00, including nodes 3050, 3051 and 3052 added for the DO furnace reviewed Quantitative Risk Analysis (QRA) 301 DSR for changes made as a result of the DO furnace installation reviewed the following TFC for the DO furnace:

o 50753 reviewed the following TOPs for the DO furnace:

o 50637 o

51030 o

51153 o

51149 OP 1030.10.100, "UO2 Sintering Furnaces #1, 3, 4, and 6 - General Information" revisions 7, 8, and 9 NS-2025-02 "ISA Reviewers - Active List" dated 03/17/2025 for current list of qualified individuals for ISA Reviews ISA Reviewer Qualification Card for one specific ISA reviewer, to verify accuracy and completeness QRA 803-804 HVAC for revision to IROFS 803-02 and 803-04 ISA revision 27 and revision 28 which documented the following:

o IROFS 402-01 through 402-016 removed per eCR 51761 o

IROFS 305-01 through 305-13 added per eCR 52425 o

IROFS 405-03 and 504-03 revised safety function per eCR 52225

12 On December 11, 2025, the inspectors presented the GNFA operational safety and permanent plant modifications (annual) inspection results to Chandi Davidson and other members of the licensee staff.

13 DOCUMENTS REVIEWED Inspection Procedure Type Designation Description or Title Revision or Date Corrective Action Documents CR 49357, 49479, 49761, 49762, 50352, 50383, 50717 Operational Safety related CAP entries Various Corrective Action Documents Resulting from Inspection eCR-54211 Revise QRA-803/804 to identify Preventative Maintenance as an applicable management measure for IROFS 803-08 Initiated 12/10/2025 Drawings 3000E8686PI1 Contaminated Waste Incinerator Offgas System P&ID Rev. 13 GLE-ENG-DB-ISA-1000001 GLE ISA Summary Rev. 18 QRA-706/704 Pads/Incinerator Rev. 16 Engineering Evaluations QRA-803/804 HVAC Rev. 27 HEPA Filter Differential Pressure Gauge Log 12/08/2025, 12/09/2025, 12/10/2025 Quality/EHS Stop Work Notice (SWN) for CR 50352 08/27/2025 IROFS 803-02 Process Equipment Barrier - Primary HEPA Housing and Ductwork Rev. 0 IROFS Surveillance 704-08 Incinerator Moderation Control Surveillance 04/28/2025 IROFS Surveillance 803-02 11/11/2025 IROFS Surveillance 803-04 10/08/2025 LS 202.02 DCP Vapo-Conversion Operating Parameters Rev. 5 88020 Miscellaneous Standard Purchase Order Purchase Order for HEPA Filter Rev. 0

14 Inspection Procedure Type Designation Description or Title Revision or Date 437162054 TD 704-08 Incinerator Moderation Controls Rev. 0 TD 704-09 Incinerator Mass Controls Rev. 0 TD 803-01 Primary HEPA Filter Monitoring Rev. 0 TD 803-03 HVAC Duct Design and Holdup Monitoring Rev. 1 TD 803-05 Primary HEPA Filtration Rev. 0 TD 803-06 Secondary HEPA Filter Monitoring Rev. 0 TD 803-07 Grinder Apitron Filters Rev. 0 TD 803-08 DSR Baghouse Filters Rev. 0 TD 803-09 Secondary HEPA Filtration Rev. 0 TD 803-10 Ductwork Inspection and Cleanout Rev. 0 TD 804-01 FMO Exhaust Scrubber System Rev. 1 TD 804-02 Scrubber Sump - Safe Geometry Rev. 0 NDE Reports Incinerator Scrubber Cleanout Sample results 2015, 2018, 2019, 2021, and 2024 dates FTI 203-12B Hydrolysis Steam Flow Verification FCV#2218 Rev. 0.1, conducted 06/28/2025 OP 1080.00 Shop Support - General Operations Rev. 1 OP 1081.01.201 Incinerator - Startup Rev. 18 OP 1081.01.202 Incinerator - Normal Operations Rev. 22 OP 1081.01.203 Incinerator - Shutdown Rev. 5 OP 1081.01.204 Incinerator - Abnormal Operations Rev. 7 OP 1240.00.205 Dry Scrap Recycle Transfer Station - Basic Operator Maintenance Rev. 3 OP 2301.00 FMO HVAC Maintenance Operation Rev. 33 Procedures WI-27-105-25 HVAC Surveys to Detect Uranium Accumulation Rev. 12 WO 5437151 Annual Repetitive: Annual Inspection of Baghouse Completed 04/10/2025 Work Orders WO 5479798 CALIBRATION FT12218 HYDROLYSIS STEAM FLOW Completed 06/27/2025

15 Inspection Procedure Type Designation Description or Title Revision or Date WO 5480007 Annual Calibration: Calibration FT12218 HYDROLYSIS STEAM FLOW Completed 08/06/2025 Corrective Action Documents CRs 44361, 49263, 49534, 49540, 50366 Condition Reports related to change management and plant modifications.

Various eCR 51761 Swarf Press Removal 12/13/2024 eCR 52225 Revise the Safety Function of IROFS 405-03/504-03 03/12/2024 eCR 52265 Modification of requirements for IROFS 101-01 UF6 Cylinder Skin Temperature 03/19/2024 eCR 52425 Direct Oxidation Furnace Installation and Operation 03/20/2024 eCR 52471 ISA Documentation Update for DO Furnace Addition 10/16/2024 ISA Reviewer Change Evaluation Form relating to eCR 52265 03/13/2024 ISA Reviewer Change Evaluation Form relating to eCR 52425 03/25/2024 ISA Reviewer Change Evaluation Form relating to eCR 52225 02/26/2024 ISA Reviewer Change Evaluation Form relating to eCR 52471 12/9/2025 Engineering Changes ISA Reviewer Change Evaluation Form relating to eCR 51761 04/25/2024 FHA 1001 Graded Fire Hazard Analysis Fuel Fabrication Operation Rev. 5 Integrated Safety Analysis Summary Rev. 28 Integrated Safety Analysis Summary Rev. 27 88070 Engineering Evaluations PHA 405-504 Sinter Node Group Rev. 12

16 Inspection Procedure Type Designation Description or Title Revision or Date QRA-0803-804 Quantitative Risk Analysis 11/20/2025 QRA-301 Dry Scrap Recycle Rev. 23 ISA Reviewer Qualification Card Rev. 4 ISA Team Meeting 1 DO Process 12/7/2023 ISA Team Meeting 2 DO Process 01/18/2024 ISA Team Meeting 3 DO Furnace 02/1/2024 ISA Team Meeting 4 DO Furnace 04/23/3034 ISA Team Meeting 5 DO Process 06/19/2024 NS-2025-02 ISA Reviewers-Active List 3/17/2025 TFC 50752 DO Furnace Operation in Press Room Rev. 1 Miscellaneous TFC 50753 ISA Manager Approval of TFC Operability Evaluations Temporary Change 50753 Inspection Requirements Pre-TOP Startup 10/4/2024 CP-06-100 Document Control Process Rev. 35 CP-16-106 Change Management Process Rev. 13 Operating Procedure 1030.10.100 UO2 Sintering Furnaces #1, 3, 4, and 6 General Information Rev. 7 Operating Procedure 1030.10.100 UO2 Sintering Furnaces #1, 3, 4, and 6 General Information Rev. 8 Operating Procedure 1030.10.100 UO2 Sintering Furnaces #1, 3, 4, and 6 General Information Rev. 9 WI-06-100-26 Controlled Access Area Temporary Operations Rev. 5 WI-16-106-01 GNF-A Change Management Process Rev. 5 Procedures WI-16-106-02 Configuration Management Program Nuclear Manufacturing Operations Rev. 23

17 Inspection Procedure Type Designation Description or Title Revision or Date WI-16-106 H01 Nuclear Manufacturing Configuration Management Role Handbook Rev. 2 WI-18-104-02 Internal Nuclear Safety Audits Rev. 7 WI-27-106-14 EHS Management of Change Rev. 4 NQA-2024-03 Audit Plan GNF-A FMO Ceramics & DCP Audit 03/26/2024 NQA-2024-03 Audit Report GNF-A FMO: Ceramics & DCP 05/24/2024 NQA-2025-05 Audit Plan GNF-A Manufacturing FMO: Bundle Assembly, CHEMET lab 04/06/2025 Self-Assessments NQA-2025-05 Audit Report GNF-A Manufacturing FMO: Bundle Assembly, CHEMET Lab 06/09/2025