ML18219B684

Mixed Oxide Fuel Fabrication Facility - NRC Inspection Report No. 0703098/2018003

ML18219B684
Person / Time
Site:	07003098
Issue date:	08/07/2018
From:	Ernstes M NRC/RGN-II
To:	Del Vecchio D CB&I AREVA MOX Services
References
IR 2018003
Download: ML18219B684 (16)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 August 07, 2018 Mr. David Del Vecchio President and Chief Operating Officer CB&I AREVA MOX Services Savannah River Site P.O. Box 7097 Aiken, SC 29804-7097

SUBJECT:

MIXED OXIDE FUEL FABRICATION FACILITY- NRC INSPECTION REPORT NUMBER 70-3098/2018-003

Dear Mr. Del Vecchio:

During the period from April 1, 2018, through June 30, 2018, the U. S. Nuclear Regulatory Commission (NRC) completed inspections pertaining to the construction of the Mixed Oxide Fuel Fabrication Facility. The purpose of the inspections was to determine whether activities authorized by the construction authorization and license application were conducted safely and in accordance with NRC requirements. The enclosed inspection report documents the inspection results. At the conclusion of the inspections, the findings were discussed with those members of your staff identified in the enclosed report.

The inspections examined activities conducted under your construction authorization and license application as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your authorization. The inspectors reviewed selected procedures and records, observed construction activities, and interviewed personnel.

NRC inspectors documented a finding of very low safety significance (SL IV) in this report. This finding involved a violation of NRC requirements. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy. If you contest the violation or significance of this NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the United States Nuclear Regulatory Commission, ATTENTION: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Senior Project Manager at the MFFF.

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 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

D. Del Vecchio 2 Should you have any questions concerning this letter, please contact us.

Sincerely,

/RA/

Michael Ernstes, Chief Construction Inspection Branch 2 Division of Construction Oversight Docket No. 70-3098 Construction Authorization No.: CAMOX-001

Enclosure:

NRC Inspection Report No. 70-3098/2018-003 w/attachment: Supplemental Information cc w/encl: (See next page)

D. Del Vecchio 3 cc w/encl:

Mr. Scott Cannon Federal Project Director NA-262.1 P.O. Box A Aiken, SC 29802 Ms. Joyce Connery, Chairman Defense Nuclear Facilities Safety Board 625 Indiana Ave., NW, Suite 700 Washington, DC 20004 Ms. Susan Jenkins Division of Radioactive Waste Management Bureau of Health and Environmental Control 2600 Bull St.

Columbia, SC 29201 Ms. Kathryn M. Sutton Morgan, Lewis, & Bockius 1111 Penn. Ave., NW Washington, DC 20004 Ms. Diane Curran Harmon, Curran, Spielburg and Eisenberg, LLP 1726 M St., NW Suite 600 Washington, DC 20036 Ms. Glenn Carroll Nuclear Watch South P.O. Box 8574 Atlanta, GA 30306 Mr. Lewis Zeller Blue Ridge Environmental Defense League P.O. Box 88 Glendale Springs, NC 28629 Mr. Dealis Gwyn, Licensing Manager CB&I AREVA MOX Services Savannah River Site P.O. Box 7097 Aiken, SC 29804-7097

D. Del Vecchio 4 Letter to D. Del Vecchio from Michael Ernstes dated August 7, 2018.

SUBJECT:

MIXED OXIDE FUEL FABRICATION FACILITY- NRC INSPECTION REPORT NO. 70-3098/2018-003 Distribution w/encl:

R. Johnson, NMSS D. Tiktinsky, NMSS M. Diaz, NMSS W. Jones, RII S. Walker, RII M. Ernstes, RII N. Coovert, RII J. Eargle, RII P. Carman, RII PUBLIC PUBLICLY AVAILABLE NON-PUBLICLY AVAILABLE SENSITIVE NON-SENSITIVE ADAMS: Yes ACCESSION NUMBER: ML18219B684 SUNSI REVIEW COMPLETE FORM 665 ATTACHED OFFICE RII: DCO RII: DCO RII: DCO RII: DFFI HQ: NMSS RII: DCO SIGNATURE Via email Via email Via email Via email Via email ME NAME P. Carman J. Eargle D. Harmon B. Adkins D. Tiktinsky M. Ernstes DATE 8/1/2018 8/1/2018 8/1/2018 8/2/2018 8/2/2018 08/07/2018

U.S. NUCLEAR REGULATORY COMMISSION REGION II Docket No.: 70-3098 Construction Authorization No.: CAMOX-001 Report No.: 70-3098/2018-003 Applicant: CB&I AREVA MOX Services Location: Savannah River Site Aiken, South Carolina Inspection Dates: April 1 - June 30, 2018 Inspectors: B. Adkins, Senior Fuel Facility Inspector, Safety Branch, Division of Fuel Facility Inspection (DFFI)

P. Carman, Project Manager, Construction Inspection Branch 2 (CIB2), Division of Construction Oversight (DCO)

J. Eargle, Senior Project Manager, CIB2, DCO D. Harmon, Construction Inspector, CIB2, DCO Accompanying Personnel: M. Ernstes, Branch Chief, CIB2, DCO W. Jones, Director, DCO D. Tiktinsky, Senior Project Manager, Fuel Manufacturing Branch (FMB), Division of Fuel Cycle Safety, Safeguards and Environmental Review (FCSE), Office of Nuclear Materials Safety and Safeguards (NMSS)

Approved by: Michael Ernstes, Chief Construction Inspection Branch 2 Division of Construction Oversight Enclosure

EXECUTIVE

SUMMARY

CB&I AREVA MOX Services (MOX Services)

Mixed Oxide (MOX) Fuel Fabrication Facility (MFFF)

NRC Inspection Report (IR) Number (No.) 70-3098/2018-003 The scope of the inspections encompassed a review of various MFFF activities related to quality level (QL)-1 (safety-related) construction for conformance to U.S. Nuclear Regulatory Commission (NRC) regulations, the Construction Authorization Request (CAR), the MOX Project Quality Assurance Plan (MPQAP), applicable sections of the License Application (LA) and applicable industry codes and standards. This inspection included, as applicable, the following inspection attributes: Installation and Special Processes (Welding).

The following principal systems, structures and components (PSSCs) are discussed in this inspection report:

• PSSC-004, C2 Confinement System Passive Barrier

• PSSC-005, C3 Confinement System

• PSSC-006, C4 Confinement System

• PSSC-009, Criticality Controls

• PSSC-050, Supply Air System Routine Resident Inspections The inspectors routinely reviewed the applicants weekly construction status package, reviewed the status of work packages maintained at various work sites, conducted daily tours of work and material storage areas, observed installation of mechanical equipment, and reviewed various corrective action documents to assess the adequacy of the MOX Services corrective action program. Construction activities were performed in a safe and quality-related manner. No violations of more than minor significance were identified. (Section 2)

PSSC Inspections PSSC-050, Supply Air System The inspectors observed installation activities and reviewed documents related to the installation of the heating, ventilation, and air conditioning (HVAC) supply air (HSA) system. The inspectors observed in-process welding, reviewed welding records and procedures, and reviewed material records associated with the work activities. No violations of more than minor significance were identified. (Section 3.a)

Follow-up of Previously Identified Items Inspector Follow-up Item 70-3098/2015-003-001, Review Criticality and Single-Parameter Spacing Analysis of Pipe Arrays in the Active Gallery The inspectors closed Inspector Follow-up Item (IFI) 70-3098/2015-003-001, Review Criticality and Single-Parameter Spacing Analysis of Pipe Arrays in the Active Gallery. No violations of more than minor significance were identified. (Section 4.a)

3 Unresolved Item 70-3098/2016-002-001, Potentially Inadequate Welds of Internal Seismic Braces in Filter Housings FLU0001B, FLU0002B, FLU0003B, FLU0004B, FLU0005B, and FLU0006B The inspectors reviewed Unresolved Item (URI) 70-3098/2016-002-001, Potentially Inadequate Welds of Internal Seismic Braces in Filter Housings FLU0001B, FLU0002B, FLU0003B, FLU0004B, FLU0005B, and FLU0006B. Based on the results of the review, URI 70-3098/2016-002-001 was closed and Non-cited Violation (NCV) 70-3098/2018-003-01, Failure to Ensure that Procured Equipment Met the Specified Requirements, was identified. This NCV was associated with the applicants failure to ensure that cross brace welds in the medium depressurization exhaust (MDE), high depressurization exhaust (HDE), and HSA filter housings met the code quality requirements. (Section 4.b)

REPORT DETAILS

1. Summary of Facility Status During the inspection period, the applicant (CB&I AREVA MOX Services (MOX Services)) continued construction activities of principal systems, structures and components (PSSCs). Other construction activities included staging of process piping and installation of supports in the aqueous polishing area (BAP); installation of process piping in the BAP; installation of ventilation system ductwork and supports in the BAP and MOX processing area (BMP); installation of fire dampers in the BAP and BMP; and installation of various gloveboxes in the BAP and BMP. The applicant continued to receive, store, assemble, and test glove boxes and process equipment at the process assembly facility (PAF).

2. Routine Resident Inspection Activities

a. Inspection Procedure (IP) 88130, Construction: Resident Inspection Program for On-Site Construction Activities at the Mixed Oxide Fuel Fabrication Facility (1) Scope and Observations The inspectors reviewed the applicants construction weekly status meeting notes. The inspectors held discussions with MOX Services design engineers, field engineers, quality assurance (QA) and quality control (QC) personnel, and subcontractor construction personnel in order to maintain current knowledge of construction activities and any problems or concerns.

The inspectors reviewed the status of work packages (WPs) maintained at various work sites. The inspectors reviewed various corrective action documents. The review included non-conformance reports (NCRs) and condition reports (CRs). The inspectors routinely performed tours of the MOX Fuel Fabrication Facility (MFFF) work areas to observe ongoing work activities and communications.

(2) Conclusions No violations of more than minor significance were identified.

3. PSSC Inspections

a. PSSC-050, Supply Air System (1) Scope and Observations The inspectors observed construction activities related to PSSC-050, Supply Air System, as described in Table 5.6-1 of the MFFF Construction Authorization Request (CAR).

The inspection attribute observed was Special Processes (Welding).

The inspectors observed in-process welding of a quality level (QL)-1 HVAC duct component for the heating, ventilation, and air conditioning (HVAC) supply air (HSA) system, weld number C206-HAS-3A1-FW002-C0R0, to determine if the welding was being performed in accordance with the applicable procedures. The inspectors reviewed

5 the weld filler metal issue slip to determine if the filler metal had been issued in accordance with the weld filler metal control procedure. The inspectors reviewed the welding procedure and procedure qualification records to determine if the procedure had been written and qualified in accordance with the requirements of American Welding Society (AWS) D9.1, Sheet Metal Welding Code. The inspectors also reviewed the welders qualification records to determine if the welder had been qualified in accordance with AWS D9.1 to make the weld. Lastly the inspectors reviewed the certified material test report (CMTR) for the weld filler metal to verify if it had been procured and tested in accordance with the requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (BPVC),Section II.

(2) Conclusions No violations of more than minor significance were identified.

4. Follow-up of Previously Identified Items

a. (Closed) Inspector Follow-up Item 70-3098/2015-003-001, Review Criticality and Single-Parameter Spacing Analysis of Pipe Arrays in the Active Gallery (1) Scope and Observations During a previous inspection in 2015, the inspectors determined that the active gallery was not covered by a specific criticality safety analysis. The inspectors noted that MOX Services was in the process of developing a detailed computer model of the active gallery to ensure that congested areas of piping and components would remain subcritical during both normal and credible abnormal conditions. The inspectors discussed the preliminary model with MOX Services during the 2015 inspection including whether there was a basis for not modeling non-fissile (e.g., water or empty) piping. The inspectors determined that further review by the NRC staff was necessary to evaluate the acceptability of the criticality and single-parameter spacing analysis for large piping arrays in the active gallery. The inspectors opened Inspector Follow-up Item (IFI) 70-3098/2015-003-001, Review Criticality and Single-Parameter Spacing Analysis of Pipe Arrays in the Active Gallery, to further evaluate the adequacy of the MOX Services criticality analysis for the active gallery.

The inspectors reviewed DCS01-KKJ-DS-CAL-H-35095-0, Criticality Safety of the MFFF Active Gallery, to verify that MOX Services adequately evaluated the potential for criticality in the active gallery. Specifically, the inspectors reviewed the computer model to ensure that it accurately reflected the piping and equipment configurations in the active gallery. The inspectors noted that the model was built off of the MFFF plant design system (PDS) model which includes thousands of fissile bearing pipe segments and components. The inspectors reviewed the analysis to verify that it contained conservative assumptions such as (1) modeling piping and components to the outside diameter, (2) no neutron absorption credit for stainless steel in the piping and racks, (3) all piping and components were simultaneously filled with fissile solution at bounding concentrations, (4) piping/components were conservatively reflected with one inch of water, and (5) optimum moderation. The inspectors reviewed the analysis to verify that the model parameters (e.g., chemical form, H/Pu, concentration, and energy of average lethargy causing fission (EALF)) were within the validated area of applicability (AOA) established in the validation report. The inspectors reviewed the results of model

6 sensitivity studies to address potential process upsets that could occur during construction. Examples reviewed included pipe or rack positioning errors, equipment location errors, wall placement errors, and changes in moderation. The inspectors reviewed the calculation results to ensure that the effective multiplication factor (Keff) met the established upper safety limit (USL) as established in the license application.

The inspectors noted that there was significant margin between the calculated Keff and the USL for all normal and credible abnormal conditions.

The inspectors also reviewed DCS01-KKJ-DS-CAL-H-35101-0, Criticality Safety of the Active Gallery Supplement. The supplemental analysis included a base case model, representative array sensitivity cases, mixed array sensitivity cases, moderation sensitivity cases, rack sensitivity cases, and pipe position sensitivity cases. The purpose of the supplemental calculations were to assess the impact of empty pipes or water pipes on reactivity (omitted from previous model), whether uniform pipe arrays (base cases) bound mixed pipe sizes (representative cases), the impact of stainless steel as an absorber, and the impact of pipe spacing tolerances on reactivity. The inspectors reviewed the original and supplemental analyses performed to determine if they provided reasonable assurance (e.g. sufficient margin - 20% below the USL) that Keff would not exceed the USL established in the license application during normal and credible abnormal conditions.

The inspectors reviewed DCS01-KKJ-CG-NTE-H-07708-A, Aqueous Polishing -

Subcritical Geometry Requirements of Pipes and Small Equipment in the Active Gallery, to verify that the generic spacing requirements contained in construction work packages will protect the assumptions assumed in the criticality analysis. The inspectors noted that no additional spacing requirements beyond standard construction tolerances are necessary for piping systems to ensure that the active gallery remains subcritical. MOX Services will perform QC inspections to verify that active gallery piping was installed in accordance with specified requirements and tolerances. The inspectors reviewed DCS01-KKJ-DS-ANS-H-35053-4, Nuclear Criticality Safety Evaluation of the AP Auxiliary Units, to ensure that the results of the criticality calculations were documented in the criticality safety evaluation.

(2) Conclusions No violations of more than minor significance were identified. IFI 70-3098/2015-003-001 is considered closed.

b. (Closed) Unresolved Item (URI) 70-3098/2016-002-001, Potentially Inadequate Welds of Internal Seismic Braces in Filter Housings FLU0001B, FLU0002B, FLU0003B, FLU0004B, FLU0005B, and FLU0006B (1) Scope and Observations During an earlier inspection in 2016, the inspectors walked down components associated with PSSC-005, C3 Confinement System, as described in Table 5.6-1 of the MFFF CAR. The inspection attributes observed were Installation and Special Processes (Welding). The associated items relied on for safety IROFS components were high depressurization exhaust (HDE) filter housings FLU0001B, FLU0002B, FLU0003B, FLU0004B, FLU0005B, and FLU0006B. Specifically, the inspectors observed the internal welds and bracing of these HDE filter housings. Unresolved Item 70-3098/2016-

7 002-001 was identified for potentially inadequate welds on the seismic cross bracing inside the filter housings.

During the current inspection period, the inspectors held interviews with the applicants engineering staff and reviewed records associated with MOX Services and AAF Flanders (Flanders) actions taken to resolve URI 70-3098/2016-002-001 to determine if a violation of NRC requirements existed. The inspectors reviewed, X-bracing Weld Defect Technical Justification MOX Filter Housings, Revision F, which was prepared by Flanders and approved by MOX Services as document number 08716-00003307_-0343, Revision I, as a technical use-as-is justification for the filter housing cross brace weld defects. Additionally the inspectors reviewed nonconformance report 10888-MOX-NCR-16-6896, receiving inspection report QC-RIR-14-51650, and Structural Integrity report 1800430.401.R0, "MOX Containment X-Bracing Weld Evaluation."

The inspectors also performed a walk down and visual inspection of the very high depressurization exhaust system (VHD) filter housings to verify if the applicant had adequately determined the scope of the issue to be limited to the HDE, medium depressurization exhaust (MDE), and HSA systems.

(2) Conclusions

Introduction:

The NRC identified a SL IV NCV for the applicants failure to ensure that procured equipment met the specified quality requirements. Specifically MOX Services failed to ensure that cross brace welds in the HDE, MDE, and HSA systems filter housings met the code quality requirements.

Description:

MOX Services procured filter housings for the HDE, MDE and HSA HVAC systems from Flanders that were seismically qualified and fabricated to ASME AG-1 Code on Nuclear Air and Gas Treatment. Flanders used a standard commercial design with cross bracing transverse to the airflow which was seismically qualified by shake testing a representative filter housing.

After the NRC issued URI 70-3098/2016-002-001 for potentially inadequate welds on the filter housings, the applicant and Flanders performed visual inspections of cross brace welds on all filter housings that had been fabricated. The inspections concluded that 28 filter housings in the HDE, MDE, and HSA systems with multiple cross brace welds had defects which exceeded the acceptance criteria of ASME AG-1.

Flanders used the detailed inspection data for the as built welds and performed an evaluation. Flanders evaluation used the detailed weld status of the filter housing that had been shake tested and relative stresses at different locations within the housings to justify accepting the filter housings as-is. MOX Services approved Flanders justification September 2017.

The NRC inspectors reviewed the Flanders evaluation in February 2018 and held discussions with MOX Services engineering staff regarding the weld defects which lay outside the bounds of the evaluation. Subsequently, MOX Services procured a computer analysis performed by Structural Integrity to demonstrate that the as built filter housings would be able to withstand the design basis earthquake. The Structural Integrity analysis was accepted by MOX Services in May 2018.

8 Analysis: Using the guidance contained in Inspection Manual Chapter 0613, Power Reactor Construction Inspection Reports, the inspectors determined that the applicants failure to ensure the quality of procured components was a more than minor finding.

Specifically the deficiency represented a substantive failure to establish or implement an adequate quality oversight function and represented an adverse condition that rendered the quality of a structure, system, or component (SSC) unacceptable and required substantive corrective action. This finding was determined to be a SL IV violation using Section 6.5, Facility Construction (10 CFR Parts 50 and 52 Licensees and Fuel Cycle Facilities) of the NRC Enforcement Policy, dated 11/01/2016, because the applicant failed to meet regulatory requirements, including one QA criteria that had a more than minor safety significance. The finding was determined to have very low safety significance because after further analysis the applicant showed the components were capable of withstanding the design basis seismic event.

Enforcement: MOX Project Quality Assurance Plan Section 7, Control of Purchased Material, Equipment, and Services, states in part that MOX Services procurement of Quality Level 1 and Quality Level 2 material, equipment and services is controlled to assure conformance with specified technical and QA requirements.

MOX Services LA and HEPA Filter Housings Procurement Specification, DCS01-QGA-DS-SPE-V-10159-6, Section 2.2.4, require that the HDE, MDE, and HSA filter housings be fabricated in accordance with ASME Code AG-1 1997.

ASME Code AG-1 1997, Code On Nuclear Air and Gas Treatment, Section 6300, Welding Requirements, requires that welds have complete fusion, have lengths as specified in design drawings, be free of cracks, and be free of porosity and undercut in excess of stated limits.

Contrary to the above, on or before August 27, 2014, MOX Services failed to adequately control procurement of Quality Level 1 and Quality Level 2 equipment to ensure conformance with specified technical requirements. Specifically, 28 filter housings were fabricated by Flanders for the HDE, MDE, and HSA systems with cracks, lack of fusion, insufficient length, and excessive porosity and undercut in the welds joining the seismic cross-bracing inside the filter housings.

This finding was determined to be a SL IV violation using Section 6.5 of the Enforcement Policy. This violation is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy. The violation was entered into the applicants corrective action program as 10888-MOX-CR-18-242 and 10888-MOX-NCR-16-6896. Additionally the applicant was planning appropriate corrective actions. (NCV 70-3098/2018-003-01, Failure to Ensure that Procured Equipment Met the Specified Requirements)

5. Exit Meeting The inspection scope and results were summarized throughout this reporting period and by the Senior Project Manager at an exit meeting with applicant management on August 7, 2018. Although proprietary documents and processes may have been reviewed during this inspection, the proprietary nature of these documents or processes was not included in this report.

SUPPLEMENTAL INFORMATION

1. PARTIAL LIST OF PERSONS CONTACTED D. Del Vecchio, President H. DeMart, Field Engineer D. Gwyn, Licensing / Nuclear Safety Manager M. Gober, Vice President Engineering D. Ivey, Project Assurance Manager R. Keeler, Acting Director of Construction / Project Management E. Radford, Regulatory Compliance Manager G. Rousseau, Deputy Project Manager / Executive Vice President J. Starling, Licensing D. Yates, Licensing

2. INSPECTION PROCEDURES (IPs) USED IP 88130 Resident Inspection Program For On-Site Construction Activities at the Mixed-Oxide Fuel Fabrication Facility IP 88139 Ventilation and Confinement Systems

3. LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Item Number Status Description 70-3098/2015-003-001 Closed IFI: Review Criticality and Single-Parameter Spacing Analysis of Pipe Arrays in the Active Gallery (Section 4.a) 70-3098/2016-002-001 Closed URI: Potentially Inadequate Welds of Internal Seismic Braces in Filter Housings FLU0001B, FLU0002B, FLU0003B, FLU0004B, FLU0005B, and FLU0006B (Section 4.b) 70-3098/2018-003-01 Opened/Closed NCV: Failure to Ensure that Procured Equipment Met the Specified Requirements (Section 4.b)

4. LIST OF ACRONYMS USED ADAMS Agency-Wide Document Access and Management System AOA Area of Applicability AP Aqueous Polishing ASME American Society of Mechanical Engineers AWS American Welding Society BAP Aqueous Polishing Building BMP MOX Processing Building BPVC Boiler and Pressure Vessel Code CAR Construction Authorization Request CB&I Chicago Bridge and Iron CFR Code of Federal Regulations CIB2 Construction Inspection Branch 2 Attachment

2 CMTR Certified Material Test Report CR Condition Report DCO Division of Construction Oversight DFFI Division of Fuel Facility Inspection EALF Energy of Average Lethargy Causing Fission ECR Engineering Change Request FCSE Division of Fuel Cycle Safety and Environmental Review FMB Fuel Manufacturing Branch HDE High Depressurization Exhaust HSA HVAC Supply Air HVAC Heating, Ventilation, and Air Conditioning IFI Inspector Follow-Up Item IP Inspection Procedure IR Inspection Report IROFS Items Relied on for Safety Keff Effective Multiplication Factor LA License Application MDE Medium Depressurization Exhaust MOX Mixed Oxide MOX Services CB&I AREVA MOX Services MFFF MOX Fuel Fabrication Facility MPQAP MOX Project Quality Assurance Plan NCR Non-conformance Report NMSS Office of Nuclear Materials Safety and Safeguards No. Number NRC U.S. Nuclear Regulatory Commission NCV Non-Cited Violation PAF Process Assembly Facility PDS Plant Design System PP Project Procedure PQR Procedure Qualification Record PSSC Principal System, Structure and Component QA Quality Assurance QC Quality Control QL Quality Level Rev. Revision RII Region II SL Severity Level SSC Structure, System, or Component URI Unresolved Item USL Upper Safety Limit VHD Very High Depressurization Exhaust System WP Work Package

5. LIST OF PSSCs REVIEWED

• PSSC-004, C2 Confinement System Passive Barrier

• PSSC-005, C3 Confinement System

• PSSC-006, C4 Confinement System

• PSSC-009, Criticality Controls

3

• PSSC-050, Supply Air System

6. RECORDS AND DOCUMENTS REVIEWED Calculations 08716-00003307_-0229, Seismic Qualification Report - Containment Housing, Revision B

DCS01-KKJ-CG-CAL-H-07731-A, Criticality Safety of the MFFF Active Gallery in Cell C234, Revision A DCS01-KKJ-CG-NTE-H-07708-A, Aqueous Polishing Subcritical Geometry Requirements Supports of Pipes and Small Equipment in the Active Gallery Cell C-234, Revision A DCS01-KKJ-DS-ANS-H-35053-4, Nuclear Criticality Safety Evaluation (NCSE) of AP Auxiliary Units, Revision 4 DCS01-KKJ-DS-CAL-H-35095-0, Criticality Safety of the Active Gallery, Revision 0 DCS01-KKJ-DS-CAL-H-35101-0, Criticality Safety of the Active Gallery Supplement, Revision 0 Certified Material Test Reports (CMTRs)

Certified Material Test Report for Weld Filler Metal Lot AF9689 Condition Reports (CRs) 10888-MOX-CR-17-202, Improperly labeled storage areas in MFFF, 5/24/2017 10888-MOX-CR-18-004, Stainless Steel HVAC Duct Passivation, 1/9/2018 10888-MOX-CR-18-152, Annual Audit of Quality Assurance FY18, 5/3/2018 10888-MOX-CR-18-164, Improper Storage of Temporary Material, 5/8/2018 FFI-16-SIR-015-03, Supplier Deficiency Report from Flanders / CSC Corporation, Revision 1 CR for NCV in Section 4 10888-MOX-CR-18-242, Inadequate Welds on HDE Filter Housings, 7/9/2018 Drawings 08716-00003307_-0091, VHD 1H1W System Floor Mount, Revision J 08716-00003307_-0093, VHD 1H1W System, Revision I 08716-00003307_-0097, VHD 1H1W System Floor Mount, Revision F Engineering Change Requests (ECRs)

ECR-027936, AP AUX NCSE, R4TBV1 Removal, 6/23/2016 ECR-028711, HVAC Cross Bracing Weld Acceptance Criteria, Revision 1 ECR-030175, Continuation of ECR 028711, HVAC Cross Bracing Weld Acceptance Criteria Revision 0

4 Inspection Reports / Plans 08716-00003307_-0360, UUT2 Inspection Data, Revision A 08716-00003307_-0361, Inspection Plan for UUT2, Revision A Miscellaneous Documents 006635, Applicability Determination for ECR-030175, 2/27/2018 Non-conformance Reports (NCRs) 08716-00003307_-0384, NCR 1100, Revision A 08716-00003307_-0394, NCR 1106, Revision C 10888-MOX-NCR-17-7558, Cleanliness of Embedded Pipe, 4/13/2017 10888-MOX-NCR-18-8171, Missing Component, 2/23/2018 10888-MOX-NCR-16-6896, Welding, 4/7/2016 Project Procedures (PPs)

PP11-52, AWS D9.1 General Welding Procedure, Revision 0 PP11-73, Cleaning and Contaminant Removal for Steel and Corrosion Resistant Alloys, Revision 1 Receipt Inspection Reports QC-RIR-14-51650, Assembly, Filter Housing, 8/27/2014 Specifications DCS01-QGA-DS-SPE-V-10159-6, Procurement Specification, HEPA Filter Housings, Quality Level 1, Revision 6 DCS01-QGA-DS-SPE-V-15890-11, Ductwork Fabrication and Installation, Quality Level 1 (IROFS), Revision 11 DCS01-ZMJ-DS-SPE-M-21402-2, Equipment Seismic Qualification Specification, Quality Level 1, Revision 1 Technical Evaluations 08716-00003307_-0208, Similarity Report - Large Containment Housings, Revision K 08716-00003307_-0343, X-bracing Weld Defect Technical Justification, Revision I 08716-00003307_-0461, MOX Containment X-Bracing Weld Evaluation, Revision A 2012-0359-SR-002, MOX Containment Housings HSA, HDE, POE, MDE, VHD, Revision 8

Weld Records and Procedures GTAW welder quals for welder S078 Procedure Qualification Record (PQR) D9.1-GT-3-SG-4G-16, 11/4/2011 PQR D9.1-GT-3-VG-4G-10, 11/4/2011 Welding Technique Sheet D9.1-GT-SS-01, Revision 0