ML23296A007

Framatome-Richland - Core Inspection Report 07001257/2023003

ML23296A007
Person / Time
Site:	Framatome ANP Richland
Issue date:	10/25/2023
From:	Eric Michel NRC/RGN-II/DFFI
To:	Stephens L Framatome
References
IR 2023003
Download: ML23296A007 (1)

Text

Lance Stephens, Site Manager Framatome Inc.

2101 Horn Rapids Road Richland, WA 99354

SUBJECT:

FRAMATOME - RICHLAND - CORE INSPECTION REPORT 07001257/2023003

Dear Lance Stephens:

This letter refers to the U.S Nuclear Regulatory Commission (NRC) inspection activities conducted from July 1, 2023, to September 30, 2023, for the Framatome-Richland fuel facility.

On July 20th, the results of the inspections were discussed with you and other members of your staff. The results of the inspections are documented in the enclosed report.

No violations of more than minor significance were identified during this inspection.

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding. To the extent possible, your response (if any) should not include any personal privacy or proprietary information so that it can be made available to the public without redaction.

Sincerely, Eric C. Michel, Chief Projects Branch 2 Division of Fuel Facility Inspection Docket No. 07001257 License No. SNM-1227

Enclosure:

As stated cc w/ encl: Distribution via LISTSERVOctober 25, 2023 Signed by Michel, Eric on 10/25/23

ML23296A007

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

OFFICE DFFI/RII DFFI/RII DFFI/RII

NAME G. Goff C. Taylor E. Michel DATE 10/23/23 10/24/23 10/25/23 U.S. NUCLEAR REGULATORY COMMISSION

Inspection Report

Docket Number: 07001257

License Number: SNM-1227

Report Number: 07001257/2023003

Licensee: Framatome Inc.

Facility: Framatome Inc. - Richland

Location: Richland, WA

Inspection Dates: July 17 - 20, 2023

Inspectors: G. Goff, Fuel Facilities Inspector M. Greenleaf, Technical Assistant T. Shewmaker, Fuel Facility Inspector T. Sippel, Senior Fuel Facility Projects

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

Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a core inspection at Framatome Inc. - Richland, 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

Type Issue Number Title Report Status Section Unresolved URI 07001257/2022-004-02 MURS Furnace Electrical 88072 Open Issue (URI) Hazard

2 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.

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 program to verify compliance with selected portions of 10 Code of Federal Regulation (CFR) 70, including 70.50, 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) to verify compliance with 10 CFR 70 and applicable sections of the license application, including 5.1, 5.3.2, 5.3.4, and 5.4.2.11. Specifically, the inspectors interviewed licensee staff and reviewed the following NCSAs:

• E04-NCSA-960, "HVAC Exhaust Systems," Version 42.0, including the review of what-if analysis, normal, credible abnormal, and non-credible accident sequences, and the basis for selected items relied on for safety (IROFS)

• E04-NCSA-720, "Uranyl Nitrate Storage Building," Version 9.0, including the review of what-if analysis, normal, credible abnormal, and non-credible accident sequences, and the basis for selected IROFS

• E04-NCSA-120, "UNH Reprocessing," Version 25.0, which was reviewed because it contained information supporting the licensee's evaluation of accident sequences and IROFS in E04-NCSA-720

• The inspectors also conducted walkdowns in the uranyl nitrate building (UNB),

the uranyl nitrate hexahydrate (UNH) area, the scrap uranium recovery facility (SURF), connections between these areas, and other areas containing fissile material

3 Criticality Implementation (IP Section 02.02)

The inspectors selected engineered and administrative IROFS from the licensees integrated safety analysis (ISA) summary to verify proper implementation through a review of process and system descriptions, plant walkdowns, and operator interviews to verify compliance with 10 CFR 70 and applicable sections of the license application, including 5.3.1. Specifically, the inspectors interviewed licensee staff and reviewed the following controls and selected applicable management measures, associated with the NCSAs listed above:

• IROFS 238, An annual sample of the UNB bulk storage tanks, which is an administrative control on concentration

• IROFS 239, A sample of the UNB bulk storage tanks when required by upstream level monitoring, which is an administrative control on concentration

• IROFS 720, During normal operations all tanks are sealed, which is a passive engineered control to control concentration

• IROFS 724, Steel guards protect UN solution transfer lines from damage if the guard is impact by powered equipment, which is a passive engineered control to reduce the probability of a spill

• IROFS 744, Exterior UNB solution transfer lines are double contained, which is a passive engineered control to reduce the probability of a spill

• IROFS 752, Location of tank drain headers prevents impact by powered equipment, which is a passive engineered control to reduce the probability of a spill

• IROFS 912.20, Appropriate and protective pipe routing minimizes collision hazard, which is a passive engineered control to reduce the probability of a spill

• IROFS 3507, Room overflow drain, which is a passive engineered control on geometry to ensure a safe-slab thickness for U-bearing liquids

• IROFS 4506, Moderation Control - HEPA filter housings, which is a passive engineered control preventing the introduction of moderator

• IROFS 4514, Vacuum System Sock Filters, which is a passive engineered control preventing the accumulation of fissile mass on the HEPA filters

• IROFS 4515, Favorable-geometry knockout pot, which is a passive engineered control preventing the accumulation of fissile mass on the HEPA filters and the introduction of moderator, instead containing such materials to a favorable geometry

• IROFS 4520, HEPA Filter Fissile Mass Loading, which is an administrative mass control, including review of SOP-40821

• IROFS 4530, HEPA filter design requirements, a passive engineered control specifying the design of the HEPA filters, including review of the procurement documentation

• IROFS 6110, Criticality Drain C100DR07, which is an engineered control that prevents backflow by directing liquid overflow to the room floor

• IROFS 6125, Floor is free from unfavorable geometry accumulation points, which is a passive engineered geometry control

4 Criticality Operational Oversight (IP Section 02.03)

The inspectors assessed the nuclear criticality safety (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. Specifically, the inspectors performed the following activities:

• interviewed licensee NCS engineers and air balance staff concerning criticality hazards and control methods, including preventing and monitoring for long-term accumulations in HVAC and HEPA filters

• observed a licensee NCS engineer conduct a weekly audit in Warehouse 2 and Warehouse 7, reviewed the audit schedule, and interviewed NCS staff about the weekly audits

• reviewed the 2023 NCS Audits records

• interviewed warehouse operators and engineers concerning criticality hazards and control methods, including moderator and mass control IROFS in the warehouses

• reviewed the 2022 Nuclear Criticality Safety Annual Refresher Training materials

Criticality Programmatic Oversight (IP Section 02.04)

The inspectors reviewed NCS program procedures, audits records, and interviewed NCS staff to verify compliance with 10 CFR 70 and applicable sections of the license application, including, 5.3.10. Specifically, the inspectors performed the following:

• reviewed HVAC inspection record: WO 13606277, "C960P001 HVAC K3 EXH SYS UO2 3Mo OPCR," dated June 16, 2023, involving visual surveys for accumulations in the ductwork

• reviewed the most recent triennial external audit of the licensee's NCS program dated July 23, 2021

• reviewed the most recent revision to licensee procedures E04-06-002, "Routine Nuclear Criticality Safety Audits," and E04-06-006, "Nuclear Criticality Safety Management System Assessment"

Criticality Incident Response and Corrective Action (IP Section 02.05)

The inspectors reviewed the licensees criticality accident alarm system (CAAS) and corrective action program (CAP) to verify compliance with 10 CFR 70 and applicable sections of the license application, including, 5.3.9, 5.3.10, and 5.5. Specifically, the inspectors observed and/or reviewed the following documents and activities:

• Reviewed CSA-608623, "HRR SITE EMERENCY RESPONSE CRITICALITY EVACUATION ROUTE"

• Recent NCS evacuation drill records for 2022 and 2023

• Observed posted Evacuation Route Map during walkdowns

• Reviewed recent NCS infractions and NCS-related CAP entries, and interviewed licensee staff concerning these items

5 88055 - Fire Protection

The inspectors evaluated selected aspects of the licensees fire protection program to determine whether the operational status, material condition, and design of fire protection systems met the applicable requirements of 10 CFR 70, Chapter 7, Fire Safety, of the facilitys license application, and applicable licensee procedures.

Selection of Inspection Samples (IP Section 02.01)

The inspectors reviewed licensing documents to select a sample of fire protection features in risk-significant areas/processes, including IROFS and their respective management measures. The inspectors also selected licensee activities that support the implementation of the fire protection program based on the program description included in the license application. Specifically, the inspectors:

• walked down IROFS 4502 and 4503; as applied to System 460 - Rod Loading, System 470 - Rod Testing, System 540 - Bundle Assembly and Storage, System 790 - Laboratories, Warehouse 7 (I3G), the UNB, and the SURF

• reviewed the "2022 Site EP Orientation for Fire Departments" given to Richland Fire Department per the emergency plan (EP)

• reviewed site training for the Plant Emergency Response Team (PERT), fire watches, and all plant employees for hands-on fire extinguisher training

• reviewed fire hazards analyses for the UO2 building and validated analytical assumptions via walk-downs of select areas of the UO2 building (Systems 460, 470, 540, and 790)

Preventative Controls (IP Section 02.02)

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

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

• conducted plant walk-downs of Laboratories, Rod Testing, Rod Loading, Bundle Assembly and Storage, Warehouse 7, UNB, and SURF to verify fire prevention and detection equipment

• reviewed preventive maintenance records (PMs) for monthly licensee walk-downs for IROFS 4503

• interviewed fire protection staff and technicians regarding various aspects of the fire protection program

• reviewed the procedure MCP-30039, "Hot Work Procedure," Revision 13

• reviewed SOP-40857, Maintenance Hot Work Permit Procedure, Revision 14

• reviewed the Hot Work Permit for work order (WO) 11578558

Fire and Gas Detection and Alarm Systems (IP Section 02.03)

The inspectors reviewed select fire detection devices to verify that detection and alarm systems were able to initiate the safety function credited in the fire hazard analysis (FHA)

6 and/or the ISA Summary. Specifically, the inspectors conducted the following inspection activities:

• walked down the Central Fire Alarm Station and display panel

• walked down other fire alarm stations and display panels

• conducted walkdowns of heat detectors in areas inspected

• interviewed engineering staff regarding the fire alarm station operation and detection capabilities

• reviewed completed preventive maintenance records (PMs) for testing heat detectors (see Documents Reviewed section)

Suppression Systems and Activities (IP Section 02.04)

The inspectors interviewed license staff, reviewed fire protection program documents, and conducted plant walk-downs to verify that suppression systems were capable of performing the safety function credited in the license application (Chapter 7). Specifically, the inspectors performed the following activities:

• walked down the sprinkler systems in Warehouse 7, select areas within the UO2 Building, and the UNB with focus on any obstructions or material degradation

• walked down the Plant Emergency Response Team (PERT) staging area and inspected that equipment staged was pertinent to postulated fire scenarios

• sampled during walk-downs that moderator restricted areas were conspicuously posted

• reviewed applicable analyses (see the Documents Reviewed section) that demonstrated that fire-fighting activities using moderator (water) would not lead to criticality in the UO2 building

• observed material condition of fire hoses and hook-ups at select locations

• observed that special nuclear material (SNM) was protected from water suppression via various enclosures

• confirmed via sampling that portable fire extinguishers were of the proper type (e.g., ABC or Class D) for the area and were in a ready state by a review of records or observations

• interviewed PERT staff to understand PERT responsibilities during fire scenarios and compared their responses to credited PERT actions expected in the fire hazards analysis

• interviewed the engineer responsible for fire suppression capabilities

• interviewed the emergency preparedness director and the environmental engineer regarding fire water run-off and drainage

• reviewed a drawing of the French drains utilized by the licensee and a mapped location for each followed by a walked down of several French drains to verify matching of the drawing and map to field locations

• reviewed maintenance records for the testing/functionality of the sprinkler systems

7 Passive Fire Protection Features (IP Section 02.05)

The inspectors reviewed selected passive fire protection features to verify these were in a proper material condition to perform the safety function credited in the license application and the ISA Summary. Specifically, the inspectors performed the following activities:

• walked down IROFS fire wall in UNB

• walked down other fire walls in selected areas

• reviewed the corrective action associated with sealing penetrations in non-IROFS fire walls, identified during the inspection, and subsequently walked down these fire walls to verify implementation of corrective actions

Fire Protection Program Elements (IP Section 02.06)

The inspectors reviewed selected fire protection program elements to verify compliance with the license requirements. Specifically, the inspectors performed the following activities:

• walked down emergency lighting in selected areas

• walked down the facility's emergency response center and PERT storage areas

• observed that PMs were being performed on emergency radios as per procedure

• interviewed emergency response staff to ensure emergency response activities for fire are conducted in accordance with analyses

• reviewed monthly PMs testing emergency lighting throughout the site

• reviewed training records for five operators and one supervisor in Rods &

Bundles

• reviewed the pre-emergency plan and conducted walk-downs for the UO2 building to verify the pre-emergency plan is accurate with respect to postulated fire scenarios and the current plant configuration

• reviewed pre-fire plan for UO2 for UO2; walked down UO2 to verify pre-fire plan is accurate with respect to the FHA

Identification and Resolution of Problems (IP Section 02.07)

The inspectors reviewed the licensees identification and resolution of fire protection issues to verify compliance with the license requirements. Specifically, the inspectors reviewed the following corrective action program entries, audits, and self-assessments:

• FRA D3SEP IG 22-012 IR, Fire Safety Inspection Report

• CR 2023-1121, False Fire Alarm Received by 3rd Party Monitoring Company, Rev. 0

• CR 2023-1605, Magnehelic Pressure Gauge in SURF on mezzanine HEPA filter housing inadvertently left of the calibration listing, 07/13/2023

• 13602768, CG06P004, Fire Safety Inspection 1 MO OPRD, 05/25/2023

• 13606140, CG06P004, Fire Safety Inspection 1 MO OPRD, 06/21/2023

• 13602770, CG06P008, Fire Safety Inspection 1 MO ALAB, 05/23/2023

• 13606142, CG06P008, Fire Inspection 1 MO ALAB, 06/23/2023

8 INSPECTION RESULTS

No issues were identified.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

• On July 20, 2023, the inspectors presented the NRC inspection results to Lance Stephens and other members of the licensee staff at an exit meeting.

9 DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or Procedure Date 88015 Corrective Action CR-2022-2787, CR-NCS-related Corrective Action Program Entries Documents 2023-0068 NCS Infractions 22-NCS Infractions Various 025,23-001, 23-002,23-003, 23-004,23-005, 23-006, and 23-007 Corrective Action CR 2023-1656 NRC Audit Inspection 2023-003: Nuclear Criticality Safety 07/20/2023 Documents - IP 88015 Resulting from Inspection Drawings 3959-K-007 HVAC K3 Exhaust System Rev. 28 CSA-607,590 Sheet Horn Rapids Rd Site General Arrangement Uranyl Nitrate Rev. 1 113 Storage Bldg CSA-608623 HRR SITE EMERENCY RESPONSE CRITICALITY Rev. 0 EVACUATION ROUTE CSA-611720, Sheet UN Storage Building Offload and TK-10 Receipt Tank Rev. 0 1 P&ID CSA-611720, Sheet UN Storage Building TK-10U Utility Tank P&ID Rev. 1 6

CSA-617,237, Sheet UN Tank Storage Building Civil Pipe Rack Rev. 0 2

Engineering E04-NCSA-720 Uranyl Nitrate Storage Building Version 9.0 Evaluations E04-NCSA-960 HVAC Exhaust Systems Version 42.0 Miscellaneous Nuclear Criticality Safety Annual Refresher Training 2022 Email from Dan Milmore to Bill Doane 09/21/2023 CR-2023-0068-02 Differential pressure level transmitters used as IROFS 4/26/2023 which are Connected to a Pressure Diaphragm JMD:22:008 After Action Report for Semi-Annual Criticality Evacuation 07/15/2022 Exercise on June 2, 2022 JMD:23:002 After Action Report for Semi-Annual Criticality Evacuation 03/06/2023 Exercise on October 20, 2022

10 Inspection Type Designation Description or Title Revision or Procedure Date JMD:23:010 Criticality Evacuation Exercise - 2nd Quarter 2023 06/09/2023 JMD:23:014 After Action Report for Semi-Annual Criticality Evacuation 06/19/2023 Exercise on June 16, 2023 Procedures E04-06-002 Routine Nuclear Criticality Safety Audits Version 7.0 E04-06-006 Nuclear Criticality Safety Management System Version 8.0 Assessment SOP-40821 Instruction Manual HEPA and Prefilter Change-outs Version 15.0 SOP-41143 SURF Mixer-Settler Operation Version 4.0 Self-E04-07-202301 NCS Audit/Inspection Report - January 2023 Version 1.0 Assessments E04-07-202302 NCS Audit/Inspection Report - February 2023 Version 1.0 E04-07-202303 NCS Audit/Inspection Report - March 2023 Version 1.0 E04-07-202304 NCS Audit/Inspection Report - April 2023 Version 1.0 E04-07-202305 NCS Audit/Inspection Report - May 2023 Version 1.0 FRA_D3SEP_IG_21-Framatome Richland - Nuclear Criticality Safety (NCS) - 07/23/2021 022_COR_SY inspection from June 28th to July 01st 2021 FRA_D3SEP_IG_21-NUCLEAR CRITICALITY SAFETY (NCS) 07/23/2021 022_IR RICHLAND HRR JUNE 28TH TO JULY 01ST, 2021 Work Orders WO 13547817 PG000221-0010 DOS TEST K3-5-1 2YR AB 3/22/2022 WO 13575403 C720P001 Functional Test UN 1 YR RE 10/27/2022 WO 13575623 C720P009 Storage Tanks Sample 12Mo OPUR 11/15/2022 WO 13587576 C960P023 HVAC K31 HEPA HSE Drain 12Mo AB 01/12/2023 WO 13587580 C960P031 HVAC K62 HEPA HSE Drain 12Mo AB 01/19/2023 WO 13589109 C190I003 Transmitter D/P UO 1 YR IN 01/11/2023 WO 13589110 C190I004 Transmitter D/P UO 1 YR IN 01/11/2023 WO 13589112 C190I005 Transmitter D/P UO 1 YR IN 01/11/2023 WO 13595075 C960P027 Tank Drain System ELO 12Mo PF 03/16/2023 WO 13595084 C960P019 UO2 Building Drain 12Mo PF 03/19/2023 WO 13606277 C960P001 HVAC K3 EXH SYS UO2 3Mo OPCR 6/16/2023 88055 Corrective Action CR-2023-0068-02 Supplemental information for pressure gauges used as 06/28/2023 Documents IROFS CR-2023-1121 False Fire Alarm Received by 3rd Party Monitoring Rev. 0 Company

11 Inspection Type Designation Description or Title Revision or Procedure Date CR-2023-1605 Magnehelic Pressure Gauge in SURF on mezzanine 07/13/2023 HEPA filter housing inadvertently left of the calibration listing Corrective Action CR-2023-1632 Cladding box blocking a fire extinguisher 07/18/2023 Documents Resulting from Inspection Drawings EMF-616,015, Sht. ADU ABB Control System DCU-6 / Frame 2 / Slot 9, Relay Rev. 2 25 Outputs EMF-616,026 Sht. 5 UNH Pellet Vacuum Transfer System Bucket Elevator Rev. 2 Elementary Diagram EMF-616,026 Sht. 6 UNH Pellet Vacuum Transfer System Bucket Elevator Rev. 0 Elementary Diagram EMF-616015, Sht. ADU ABB Control System DCU-6 l Frame 2 l Slot 12 Rev. 03 28 Relay Outputs EMF-616017, Sht. UNH Processing Facility Powder Vacuum Transfer Rev. 003 0003 OF System Electrical Plan, Details EMF-616649, Sht. 3 Fire Alarm Wiring Diagram Device Riser Rev. 002 EMF-616649, Sht. 5 Fire Alarm System Wiring Diagram NAC Riser Rev. 0 EMF-616649, Sht. 6 Fire Alarm System Heat Detection & Pull Station Location Rev. 1 Plans EMF-616649, Sht. 7 Fire Alarm System Heat Detection & Pull Station Location Rev. 003 Plans F0903078 F0903078 Rev. C F0905666, Sht. 1 F0905666 Rev. A Engineering E04-NCSA-470 Criticality Safety - NCSA, UO2 Rod Testing Version 10.0 Evaluations E04-NCSA-540 Criticality Safety - NCSA, Bundle Assembly & Storage Version 16.0 E24-01-199 Fire Protection - Fire Hazards Analyses Version 8.0 Fire Plans E08-05-2.1 Emergency Preparedness - Pre-Emergency Plan Version 3.0 Miscellaneous Magnehelic Readings for HEPA Filter Banks (whole site) 07/15/2023 E04-NCSS-G06 Fire Prevention and Firefighting Version 32.0 E08-04-2.7 Memorandum of Understanding - Richland Fire 08/2018 Department E10-08-001 NRC Materials License SNM-1227 Version 2.0

12 Inspection Type Designation Description or Title Revision or Procedure Date E14-02-004 Hazards Analyses - Fire Hazards Analyses Version 9.0 E15-01-1 Integrated Safety Analysis - ISA Summaries Version 28.0 E15-01-2.16 Integrated Safety Analysis - ISA Summaries Version 21.0 E15-01-2.9D Integrated Safety Analysis - ISA Summaries Version 20.0 F-WI-02-009-1 Certificate of Conformance: AAF Flanders Order 05/23/2023

1. 1102810 General Employee Emergency Response 08/25/2022 Training (GET)

Hot Work Permit Hot Work Permit for WO 11578558 07/14/2023 HRR-EP-200005 PERT (Plant Emergency Response) 2023 Hands-On Fire 06/09/2023 Extinguisher Training Lesson Plan and Attendance Report HRR-EP-200006 PERT (Plant Emergency Response Team) Self Contained 11/02/2022 Breathing Apparatus Training Lesson Plan and Attendance Report HRR-IND-100070 2023 Hands-on Fire Extinguisher Training Lesson Plan 06/09/2023 and Attendance Report for Hot Work Permit Fire Watch Personnel HRR-IND-500000 PERT (Plant Emergency Response Team) Hands-on Fire 06/09/2023 Extinguisher Training Lesson Plan and Attendance Letter from JM Deist 2023 Hands-On Fire Extinguisher Training for Hot Work 06/09/2023 to Site Manager, Permit Fire Watch Personnel - Attendance Report PEDs, ICs MWP/PJB - 17550 Maintenance Work Permit/Pre-Job Briefing (ECN, IRM/PM 07/17/2023 Numbers: 9045)

NA HRR Site EP Orientation for Fire Departments Training 05/05/2022 Procedures E08-05-2.1 UO2 Building Pre-Emergency Plan Rev. 3 E08-05-2.10 Warehouse 7 Pre-Emergency Plan Rev. 4 E08-05-2.4 Engineering Laboratory Office Building Pre-Emergency Rev. 4 Plan MCO-30532 General Instructions - Process Specifications, Essential Version 6.0 Materials Class III: HEPA Filters MCP-30031 Flammables and Combustible Liquids/Solids Storage and Rev. 14 Handling MCP-30039 Hot Work Procedure Rev. 13

13 Inspection Type Designation Description or Title Revision or Procedure Date SOP-40857 Maintenance Hot Work Permit Procedure Rev. 14 SOP-41044 Designated Hot Work Area Requirements Rev. 8 Self-FRA_D3SEP_IG_22-Fire Safety Inspection Report Assessments 012_IR Work Orders 13594848 PM003884 Emergency Lights 1 MO EL 03/28/2023 13594927 PM005113 FA UO2/DRYCON EST3 FUNC 5Y EL 03/28/2023 13598701 CG06P015 Fire Extinguishers 1MO AB 05/01/2023 13598701 CG06P015 FIRE EXTINGUISHERS 1MO AB 04/29/2023 13602566 PM005510 FA S EST/HEAT/PULL VIS 1 YR EL 05/24/2023 13602702 PM 003884 Emergency Lights 1 MO EL 05/04/2023 13602711 Fire Hydrant Flow Test 12MO PS (for fire sprinkler 05/10/2023 hydraulic calculations) 13602754 CG06P015 Fire Extinguishers 1MO AB 05/30/2023 13602754 CG06P015 FIRE EXTINGUISHERS 1MO AB 05/30/2023 13602768 CG06P004 Fire Safety Inspection 1MO OPRD 05/25/2023 13606060 PM 003884 Emergency Lights 1 MO EL 06/07/2023 13606140 CG06P004 Fire Safety Inspection 1MO OPRD 06/21/2023 13611682 PM000091 Emergency Reposit 1 MO SA 07/10/2023 PM 005110 FA UO2/DRYCON EST3/HEAT/PULL FUNCTIONAL Rev. 2 INSP 5Y EL Work Order PM 003884 Emergency Lights 1 MO EL 03/19/2023 13594848 Work Order PM 003884 Emergency Lights 1 MO EL 04/02/2023 13598650 Work Order CG06P008 Fire Safety Inspection 1MO ALAB 05/23/2023 13602770 Work Order CG06P008 Fire Inspection 1MO ALAB 06/23/2023 13606142

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