ML19214A116

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Framatome, Inc., Nuclear Regulatory Commission Integrated Inspection Report 07001257/2019003
ML19214A116
Person / Time
Site: Framatome ANP Richland
Issue date: 08/02/2019
From: Eric Michel
NRC/RGN-II/DFFI
To: Land R
Framatome
References
IR 2019003
Download: ML19214A116 (20)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 August 02, 2019 Dr. Ronald J. Land Site Manager Framatome Inc.

2101 Horn Rapids Road Richland, WA 99354-0130

SUBJECT:

FRAMATOME INC. - NUCLEAR REGULATORY COMMISSION INTEGRATED INSPECTION REPORT 70-1257/2019-003

Dear Dr. Land:

This letter refers to inspections conducted from April 1 - June 30, 2019, at the Framatome Inc.,

facility in Richland, Washington. The purpose of these inspections was to perform routine reviews of the performance areas of radiological controls and facility support. The enclosed report presents the results of these inspections. At the conclusion of the inspections, the results were discussed with members of your staff at exit meetings held on April 25th and May 9th.

Based on the results of these inspections, the Nuclear Regulatory Commission (NRC) has determined that no violations of more than minor significance were identified.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice and Procedure," a copy of this letter and its enclosure, will be made available electronically for public inspection in the NRC Public Document Room or from the NRC's Agencywide Documents Access and

2 Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.

If you have any questions, please contact Richard Gibson of my staff at 404-997-4718.

Sincerely,

/RA/

Eric C. Michel, Chief Projects Branch 2 Division of Fuel Facility Inspection Docket No. 70-1257 License No. SNM-1227

Enclosure:

NRC Inspection Report 70-1257/2019-003 w/

Attachment:

Supplemental Information cc: (See page 2)

3 cc:

Calvin D. Manning, Manager Licensing and Compliance Framatome Inc.

2101 Horn Rapids Road Richland, Washington 99354 William L. Doane, Jr., Manager Nuclear Criticality Safety Framatome Inc.

2101 Horn Rapids Road Richland, Washington 99354 Timothy J. Tate, Manager Environmental, Health, Safety & Licensing Framatome Inc.

2101 Horn Rapids Road Richland, Washington 99354 Mike Elsen, Director Office of Radiation Protection Department of Health PO Box 47827 Olympia, Washington 98504-7827 Mike.Elsen@doh.wa.gov Earl Fordham, Deputy Director Office of Radiation Protection Department of Health 309 Bradley Boulevard, Suite 201 Richland, Washington 99352

ML19214A116 OFFICE RII: DFFI RII: DFFI RII: DFFI RII: DFFI RII: DFFI RII: DFFI SIGNATURE Electronically Electronically Electronically Electronically Electronic Electronically NAME M. Ruffin D. Anderson E. Michel RGibson GGoff P. Startz DATE 06/25/2019 06/19/2019 07/29/2019 07/29/2019 05/22/201 06/28/2019 E-MAIL YES NO YES NO YES NO YES NO YES YES NO OFFICE RII: DFFI RII: DFFI RII: DFFI SIGNATURE Electronically Electronically Electronically NAME P. Glenn O. Smith L. Cooke DATE 07/22/2019 07/01/2019 06/24/2019 E-MAIL YES NO YES NO YES NO

U. S. NUCLEAR REGULATORY COMMISSION REGION II Docket No.: 70-1257 License No.: SNM-1227 Report No.: 70-1257/2019-003 EPID No.: 1-2019-003-0072 Licensee: Framatome Inc.

Facility: Richland Facility Location: Richland, Washington 99354 Dates: April 1 - June 30, 2019 Inspectors: D. Anderson, Fuel Facility Project Inspector (A.1)

G. Goff, Fuel Facility Project Inspector (A.2)

M. Ruffin, Fuel Facility Project Inspector (A.3)

L. Cooke, Fuel Facility Project Inspector (Trainee) (B.1)

P. Glenn, Fuel Facility Project Inspector (B.1)

O. Smith, Senior Physical Security Inspector (B.1)

P. Startz, Fuel Facility Project Inspector (B.1)

Approved by: E. Michel, Chief Projects Branch 2 Division of Fuel Facility Inspection Enclosure

EXECUTIVE

SUMMARY

FRAMATOME INC.

NRC Integrated Inspection Report 70-1257/2019-003 April 1 through June 30, 2019 Inspections were conducted by regional inspectors during normal shifts in the performance areas of radiological controls and facility support. The inspectors performed a selective examination of licensee activities that were accomplished by direct observation of safety-significant activities and equipment, tours of the facility, interviews and discussions with licensee personnel, and a review of facility records.

Radiological Controls

  • No violations of more than minor significance were identified related to the Radiological Protection Program. (Paragraph A.1)
  • No violations of more than minor significance were identified related to the Effluent Control and Environmental Protection Program. (Paragraph A.2)
  • No violations of more than minor significance were identified related to the Transportation Program. (Paragraph A.3)

Facility Support

  • No violations of more than minor significance were identified related to the Evaluation of Exercise and Drills. (Paragraph B.1)

Attachment:

Key Points of Contact List of Items Opened, Closed, and Discussed Inspection Procedures Used Documents Reviewed Acronyms and Initialisms 2

REPORT DETAILS Summary of 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.

A. Radiological Controls

1. Radiation Protection (Inspection Procedure (IP) 88030, Appendix B)
a. Inspection Scope The inspectors performed this inspection module to determine whether the licensees performance was in accordance with the requirements of 10 CFR 20 with focus on the regulatory requirements and compliance with the requirements established in the applicable chapters of the license application (LA).

The inspectors reviewed the licensees as low as reasonable achievable (ALARA) program to determine if the program was developed and implemented in accordance with the license conditions and 10 CFR 20. The inspectors reviewed internal and external audits to verify that the radiation protection (RP) program was being reviewed at least annually. The inspectors verified that the licensee conducted ALARA Committee meetings which detailed ALARA goals and exposure summaries to identify undesirable trends. The inspectors also reviewed the 2017 ALARA Report to verify whether the report met the requirements of the license application. At the time of the inspection the 2018 ALARA Report was in the process of being finalized.

The inspectors verified that the licensee used administrative and engineered controls to limit occupational doses to ALARA per 10 CFR 20. The inspectors also reviewed the licensees ventilation program to verify it was implemented per Chapter 4. Inspectors also reviewed recently revised radiological protection procedures to verify whether the changes were in compliance with the license requirements in Chapter 11.

The inspectors conducted interviews and reviewed dose tracking data from 2018 to the present to verify that exposure records were maintained in accordance with 10 CFR 20.

In addition, the inspectors reviewed the in-house urine bioassay program and external whole body counting program. The inspectors verified the licensee had a program in place for a declared pregnant woman to meet the requirements of 10 CFR 20. The inspectors also verified the dosimetry provider was accredited by the National Voluntary Laboratory Accreditation Program (NVLAP).

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The inspectors reviewed the respiratory protection program to verify that the program was in compliance with 10 CFR 20, the LA, and applicable procedures. The review included the evaluation of ongoing decontamination, refurbishment, and calibration activities in the respirator facility. The inspectors reviewed documentation and interviewed licensee personnel to verify that the respiratory protection program adequately identified potential hazards and that users were properly trained, qualified, and re-qualified in the use of respiratory protection equipment. In addition, inspectors observed the administration of the medical fit test for respiratory equipment and reviewed fit test reports.

The inspectors reviewed the licensees air sampling program for monitoring concentrations of radioactive material and the inclusion of the data into internal dose calculations for workers. The inspectors discussed the management of the air sampling program with the RP staff and air balance operators, which included a discussion of air sampling locations and assignment of dose based on an operators time in a specific airborne radioactivity area. The inspectors also verified that applicable areas were posted in accordance with 10 CFR Part 20, and that the Notice to Employees, NRC Form 3, was posted in high traffic areas (near employee entrances/exits) in accordance with 10 CFR 19.

The inspectors reviewed the licensees bioassay program and the adequacy of personnel internal exposure assessments to verify compliance with Chapter 4. The inspectors reviewed procedures and documentation associated with internal exposure calculations, which included the input of data from the air sampling program and bioassay data from in-vitro and in-vivo results as applicable. The inspectors interviewed the individuals responsible for the review and maintenance of bioassay exposure records and internal exposure calculations to verify they were knowledgeable of the process and program requirements.

The inspectors reviewed a sample of corrective action program entries since the last RP inspection in 2018 to verify that the licensee was identifying RP program issues, including safety-significant events, at an appropriate threshold; and that corrective actions were implemented in accordance with program procedures.

b. Conclusion

No violations of more than minor significance were identified.

2. Effluent Control and Environmental Protection (IP 88045)
a. Inspection Scope The inspectors reviewed the licensees effluent control and environmental protection program to determine that the program was in accordance with the requirements of 4

10 CFR Part 20 and compliance with the applicable chapters of the LA. Specifically, the inspectors reviewed environmental program documents, observed program activities, and conducted interviews to verify that the program was being implemented in accordance with the requirements in the aforementioned documents.

The inspectors discussed if there had been any changes to the environmental program organization and reviewed personnel technical qualifications to determine compliance with Chapter 2. The inspectors also reviewed the training records for personnel performing environmental sampling to determine that these individuals were qualified and maintained their qualifications in accordance with Chapter 11.

The inspectors interviewed licensee staff to evaluate potential new areas of contamination in the surrounding environment and subsurface of the facility. The inspectors reviewed pertinent documents (see attachment) in order to determine that the licensee, to the extent practical, conducted operations that minimized the introduction of residual radioactivity into the local environment surrounding the facility, including subsurface soils and groundwater, in accordance with 10 CFR 20. The inspectors also reviewed documentation (see attachment) that demonstrated that the licensee, upon potential site closure, is prepared to remove all contamination that may remain after initial cleanup with emphasis on inaccessible areas.

The inspectors reviewed internal quarterly audits and an external triennial assessment to verify that the reviews were completed in accordance with Chapter 11. Inspectors noted any findings or observations were placed into the licensees corrective action program (CAP).

The inspectors reviewed samples of corrective action program entries. These entries were reviewed to determine whether the licensee was identifying environmental program issues at an appropriate threshold, entering them into the corrective action program, and implementing corrective actions as required by the Chapter 11.

The inspectors observed the licensee obtaining liquid/sewer samples from the Plant Effluent Management System (PEMS) and gaseous effluent samples from the environmental air sampler and five stacks (K-06, K-60, K-49, K-50, and K-55) affiliated with the Specialty Fuels (SF) Building to verify that these activities were done in accordance with procedures (see attachment). The inspectors also observed the pH meter, liquid flow meter, and rotatmeters and reviewed maintenance history for this equipment to determine proper calibration and functional checks were performed at the proper frequency as per 10 CFR 20, Chapter 11, and procedures (see attachment).

The inspectors observed the chain-of-custody of these effluent samples to on-site laboratories, which analyzed liquid/sewer and gaseous effluents for activity levels, to determine the quality control of internal laboratory functions were implemented in 5

accordance with procedures. Specifically, the inspectors observed labeling, sample transfer, sample analysis equipment, and data management. Inspectors noted that the data from these environmental samples were placed into the Laboratory Information Management System (LIMS). The analytical equipment observed was found to be within calibration as required by 10 CFR 20.

The inspectors reviewed the 2018 semi-annual effluent reports to evaluate compliance with 10 CFR 70. The inspectors also reviewed the airborne portion of the public dose assessment to verify compliance with the As Low As Reasonably Achievable (ALARA) constraint required by 10 CFR 20. In addition, the inspectors verified that the average annual effluent concentrations released in 2018 did not exceed the values specified in Table 2 of Appendix B in 10 CFR 20. Furthermore, the inspectors reviewed the concentrations of liquid releases discharged to the sanitary sewer and subsequently off-site to determine compliance with 10 CFR 20 and Table 3 of Appendix B in 10 CFR 20.

The inspectors also reviewed the 2018 external radiation source measurements, taken from dosimeters positioned along the licensees property boundary, to verify that the total dose to individual members of the public likely to receive the highest dose from licensed operations did not exceed the regulatory limit in 10 CFR 20 for calendar year 2018. The inspectors observed that the licensee maintained records of all effluent discharges to comply with 10 CFR 20.

The inspectors reviewed sampling results/records for soil, forage, and groundwater to evaluate compliance with procedures and Chapter 9 of the LA. The inspectors also reviewed the annual dose report to the Washington (state) Department of Health in order to confirm compliance with the EPAs Part 190 requirement (see IP 88045 section 02.12 Public Dose Analysis (b)(2)).

The inspectors also walked-down the cylinder recertification facility to verify that no introduction of hydrogenous lubricant (oil) could be entrained in the supply of nitrogen used to dry the interior of the 30B cylinders. This issue is addressed in 005-210 Accident Sequence as an environmental accident in Chapter 13 of the ISA Summary.

b. Conclusion

No violations of more than minor significance were identified.

3. Inspection of Transportation Activities (IP 86740)
a. Inspection Scope The inspectors evaluated whether the licensee had established, maintained, and implemented a management-controlled program to verify radiological and nuclear safety in the receipt, packaging, and delivery of licensed radioactive materials. The inspectors reviewed the licensees transportation program and program procedures to verify 6

activities were in compliance with the applicable NRC, 10 CFR Parts 20 and 71, and Department of Transportation (DOT) (49 CFR Parts 171-178) regulations.

The inspectors observed the completion of a package compliance summary and reviewed shipping records involving the shipment and receipt of licensed material to verify the licensee included appropriate documentation with the packages being shipped.

The inspectors also reviewed the shipment records to verify the licensee recorded the required information on the packaging and shipping orders including the transportation index, criticality safety index, package activity, labeling, and placards.

The inspectors observed packaging and transportation specialists perform a radioactive assay in preparation for the shipment of 30B cylinders to verify the licensee prepared shipments in accordance with procedures (see attachment). The inspectors also observed packaging and transportation specialists refurbish containers to verify the licensee ensured packages were acceptable for shipment as per 10 CFR 71 and 49 CFR 173 regulations.

The inspectors reviewed the training records to verify the licensee administered hazardous materials transportation training to applicable personnel in accordance with DOT 49 CFR 172 and the license. The inspectors observed a shipping and receiving specialist prepare 30B cylinders for shipment. The inspectors also observed a bundle packing pre-job brief and the preparation of fresh fuels in containers for shipment to their customers to verify the shipment was prepared in accordance with procedures (see attachment).

The inspectors reviewed the licensees transportation program records to verify the licensee met the 10 CFR 71 conditions required to use the general license provision for transport of licensed material. The inspectors reviewed audits of the transportation program to verify the licensee performed audits of the program in accordance with Chapter 11.

The inspectors reviewed the licensees corrective action program (CAP) entries in the area of transportation for the past 24 months to determine if deviations from procedures and unforeseen process changes affecting transportation were documented and investigated promptly in accordance with License Application Chapter 11 and to verify audit results were appropriately addressed in the CAP. The inspectors reviewed the licensees Quality Assurance Program for packages, observed that it included control of non-conforming packages, and confirmed the control of non-conforming packages in the field.

b. Conclusion

No violations of more than minor significance were identified.

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B. Facility Support

1. Emergency Exercise Evaluation (Inspection Procedure 88051)
a. Inspection Scope The inspectors evaluated select portions of the licensees emergency preparedness program specifically related to the 2019 biennial emergency exercise to verify compliance with select portions of 10 CFR Part 70 as well as the facilitys LA, emergency plan (EP), and emergency plan implementing procedures (EPIPs). The inspectors evaluated the licensee in the following areas: exercise planning; exercise execution and emergency plan implementation; and critiques, exercise control, and identification and resolution of problems.

The emergency exercise was conducted on April 24th, 2019. The scenario involved a criticality evacuation drill immediately followed by a simulated active shooter scene, simulated bomb threat, and hostage situation which required offsite police response.

The active shooter incident included casualties and injured victims requiring onsite medical treatment and simulated transfer to the hospital. The exercise resulted in an initial declaration of an alert subsequently followed by a site area emergency.

Additionally, there were activations of the emergency operations center (EOC), plant emergency response team (PERT), and plant emergency response management team (PERMT).

Prior to and in preparation for the biennial emergency exercise, the inspectors reviewed the 60-day and final exercise packets submitted by the licensee, a sample of exercises previously conducted, and interviewed licensee staff responsible for implementation of the facilitys EP to verify that the exercise was being conducted at the required frequency; included an accident scenario that was probable for the site; that exercise details and objectives were not disclosed to participants; and that offsite response organizations were invited to participate in the exercise. Specifically, the inspectors reviewed the detailed emergency scenario and timeline, exercise objectives, and prepared injects and discussed the exercise with the licensees lead controller, controllers, and evaluators to verify that the drill was planned in accordance with the EP and EPIPs.

Onsite, the inspectors conducted a plant walkdown focusing on the exercise scenario to verify that equipment and communication aids associated with the exercise were not pre-staged. Additionally, the inspectors observed pre-exercise briefings with the controllers, evaluators, and select players to determine expectations for the extent of exercise-play, exercise control, and potential contingencies for the exercise.

During the execution of the exercise, the inspectors observed emergency management command and control by the plant emergency director (PED) and incident commander 8

(IC) to verify that actions were taken to deploy resources to respond to the event, mitigate the emergency situation effectively, and were in accordance with associated procedures as required. The inspectors observed PERT and PERMT staffing and activation of the EOC to verify that the EOC was activated in the timeframe required and staffed with the required positions. The inspectors observed active event assessment and classification determinations; notifications issued; and onsite and offsite communication. The aforementioned was performed to verify that relevant safety disciplines were involved in the assessment process; initiating conditions and emergency action levels were understood and correctly identified, classifications were made within 15 minutes, state and local notifications within 15 mins, NRC notification within 60 minutes, and onsite personal notified as needed and or as conditions changed as required.

The inspectors observed the PERMT and PERTs protective action decisions (PADs) and recommendations (PARs) to verify that the PADs/PARs were implemented onsite and or shared with offsite support and reevaluated as conditions changed during the exercise. The inspectors also observed security, accountability, and the PERMT and PERTs interaction with offsite response personnel to verify that established memorandums of understanding (MOU) were executed, unified command was established, PARs were shared with the offsite responders, scene and site access was controlled, and accountably was accomplished as required by EPIPs.

The inspectors observed press releases and briefings to verify that correspondence was drafted and approved by the PED as required and that periodic briefings were conducted in the EOC and at the incident command post as required and to maintain command and control. The inspectors also observed recovery and re-entry planning to verify that termination criteria were assessed, including a path forward for restarting the plant and resumption of normal operations when appropriate.

The inspectors observed the licensees critique post the emergency exercise and reviewed the players after-action reports to verify that the licensee evaluated the emergency plan, implementing procedures, facilities, equipment, training of personnel, and overall effectiveness of the emergency response. Additionally, the inspectors reviewed the corrective actions generated following the exercise to verify that the licensee captured the items identified from the critique process and had established a path forward for correction. The corrective actions from the exercise are being tracked by the licensee as: CR 2019-1141.

b. Conclusion

No violations of more than minor significance were identified.

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C. Exit Meeting The inspection scope and results were presented to members of the licensees staff at various meetings throughout the inspection period and were summarized on April 25, 2019, and May 9, 2019, to R. Land and staff. No dissenting comments were received from the licensee. Proprietary information was discussed but not included in the report.

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SUPPLEMENTAL INFORMATION

1. KEY POINTS OF CONTACT Name Title K. Aman Tech 3 Technician J. Deist Emergency Preparedness S. Delawder Lead Health and Safety Technician (HST)

M. Deleon Packaging and Transportation Specialist J. Dunton Packaging and Transportation Specialist B. Flanagan Manager, Packaging and Transportation C. Gooldy Radiation Safety/HST Supervisor R. Hardesty Chemist T. Harmon Health and Safety Technician R. Lansing SURF Construction Manager P. Lee Maintenance Coordinator/SAP administrator L. Maas Retired, Former Licensing & Compliance Manager C. Manning Licensing and Compliance Manager T. Ogle Packaging and Transportation Specialist J. Perryman Environmental Engineer D. Pidcock HST C. Royce Health Physicist V. Sakach Health Physicist T. Tate Environmental, Health, Safety, and Licensing Manager S. Till Re-Certification Operator

2. LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED None
3. INSPECTION PROCEDURES USED 86740 Inspection of Transportation Activities 88030 Radiation Protection (Appendix B) 88045 Effluent Control and Environmental Protection 88051 Evaluation of Exercises and Drills
4. DOCUMENTS REVIEWED Records:

2nd 2018 SH-1 Regulated Shipment Biannual Audit, dated 4/18/2019 2017 ALARA Report 2018 Semi-Annual Effluent Reports (10 CFR 70.59 reports)

AID-10094, Reference 101 Dwyer Flowmeters for Room Air Samples, Version 5.0 AID-10116, Reference 176 ISCO 4230 Bubbler Flowmeter - for Plant Effluent Monitoring Station, Version 2.5 AID-10253, Reference 523 Yokogawa pH Analyzer Model PH400-P-U1-AU, Version 2.5 Attachment

ALARA Committee Meetings from June 2018 to January 2019 (various)

Annual Dose Report to Washington Dept. of Health, 06/19/2017, for satisfying the Calibrations/PMs:

IRM02080, Flowmeter (stacks) (12-month requirement)

IRM04200, Analyzer (PEMS) (monthly, 12 reviewed, 5/18-4/19)

IRM04300, Flowmeter (liquid/sewer) (monthly, 12 reviewed, 5/18-4/19)

PM003844, Sample Waste 12MO EL (annual requirement)

E05-01-020, The ALARA Report - January 1, 2017 - December 31, 2017, Version 1.0 E05-12-201805, Surveillance Audit Reports (HP-1) - May 2018 Audit, Version 1.0 E05-12-201806, Surveillance Audit Reports (HP-1) - June 2018 Audit, Version 1.0 E05-12-201807, Surveillance Audit Reports (HP-1) - July 2018 Audit, Version 1.0 E05-12-201808, Surveillance Audit Reports (HP-1) - August 2018 Audit, Version 1.0 E05-12-201809, Surveillance Audit Reports (HP-1) - September 2018 Audit, Version 1.0 E05-12-201810, Surveillance Audit Reports (HP-1) - October 2018 Audit, Version 1.0 E05-12-201811, Surveillance Audit Reports (HP-1) - November 2018 Audit, Version 1.0 E05-12-201812, Surveillance Audit Reports (HP-1) - December 2018 Audit, Version 1.0 E05-12-201901, Surveillance Audit Reports (HP-1) - January 2019 Audit, Version 1.0 E05-15-201801, Radiation Protection Audit Report (HP-4) - 2018 Audit, Version 1.0 E05-16-201801, ALARA Audit Report (HP-5), Version 1.0 E05-17-201802, Airborne Audit Report (HP-6), Version 1.0 E05-18-201801, Environmental Audit Report (HP-7) (2018 Q1 Audit), Version 1.0, February 2018 E05-18-201802, Environmental Audit Report (HP-7) (2018 Q2 Audit), Version 1.0, May 2018 E05-18-201803, Environmental Audit Report (HP-7) (2018 Q3 Audit), Version 1.0, September 2018 E05-18-201804, Environmental Audit Report (HP-7) (2018 Q4 Audit), Version 1.0, December 2018 E05-18-201901, Environmental Audit Report (HP-7) (2019 Q1 Audit), Version 1.0, 2/15-3/14/2019 E05-21-201802, Bioassay Audit Report (HP-10), Version 1.0 E05-23-201801, Sources Audit Report (HP-12), Version 1.0 E05-24-201901, Training Audit Report (HP-13), Version 1.0 E05-26-201901, Instrument Audit Report (HP-15), Version 1.0 E06-09-011, 2018 Annual Groundwater Report, Version 1.0 E08-01-1.0 Version 13.0, Emergency Plan E08-03-4.2 Version 15.0, Incident Notification Worksheet E08-03-5.1 Version 5.2, After Action Reports Environmental Dosimeter Results by Quarters for CY 2018 EPAs Part 190 requirement Fit Test Report, dated April 25, 2018 Fit Test Report, dated June 26, 2018 MAP-12 Vogtle-VOG221-PWRfuelshipment-01-22-2019 Order 1141070: MONITOR PCM, SF 153 MENS CHNG RM, dated October 23, 2018 Order 13378754: IG000024-0065, METER SURVEY (GM) 6 MO IN dated June 27, 2018 Order 13395725: IG000030-0005, CONT MONITOR 6 MO IN, dated November 14, 2018 Order 13400146: IG000024-0001, METERE RADIATION SURVEY 177-61 GM, dated December 11, 2018 2

Order 13401647: IRM 02080, FLOWMETER 1MO IN, dated January 20, 2019 Order 13401808: IG000029-0002, HAND & FOOT COUNTER Y2 IN, dated January 16, 2019 Order 13402101: IG000044-0004, MONITOR PCM SF 6 MO IN, dated January 17, 2019 Order 13402102: IG000044-0003, MONITOR PCM UO2 6 MO IN, dated January 23, 2019 Order 13402169: IG000044-0006, CONT MONITOR ELO 6 MO IN, dated January 23, 2019 Order 13405416: IG000029-0001, COUNTER, HAND AND FOOT, dated January 31, 2019 Order 13409093: IG000033-0001, A/B AIR SAMPLER 6 MO IN, dated September 9, 2018 Order 13412793: IG000030-0003, MONITOR PCM Y2 CALIN, dated April 5, 2019 Order 13416854: PM 005067, SCBA Inspection 1MO SA, dated May 7, 2019 PPE Software Engineer Data Change Request (Stack Recounts for July 24, 2018 -

September 11, 2018)

Radiological Safety Records Radiation Survey Report, WHS Fenceline/Office Building MicroRem Survey, 04/04/2019 SEAWestern, Annual SCBA Flow Test, dated March 20, 2018 and June 5, 2018 SH-2, Annual Licensed Packaging Audit, dated 10/24/2018 Shippers Reference 20009141/80012784 Soil-104 Final Report (Soil Study), 12/03/2018 Spreadsheet of Fission Products Lab Results by Gamma Analysis, January 2019 -

April 2019 Survey from UX-30 Empty Capenhurst-UF6 shipment-01-15-2019 Survey from SP-1 Kuogheng-KSH127-BWR fuel shipment, dated 02/26/2019 Survey from TN-B1 BFE2-21 2192.NP1.002.00.01-12, dated 1/25/2019 TN-B1 BFE2-21 21913.NP1.002.00.01-12-1-25-2019 Training Records for HSTs for SOPs 40031 and 40032 Triennial Rad & Environmental Assessment, May 18, 2018 US Fuel Internal Audit Report No 16:53, dated 9/2/16 UX-30 Heel LES-UF6shipment-11-05-2018 Procedures:

ADM-00003, HST Training and Certification Procedures, Version 6.0 AID-10094, Reference 101 Dwyer Flow Meters for Room Air Samples, Version 5.0 AID-10409, Reference 1083 Canberra Argos - 4AB&5AB, Personnel Contamination Monitors, Version 5.0 E11-01-004 Radioactive Material Shipping Standard, Version 32 E12-03-026, Transportation-Regulated Shipment Audit, Version 4.3, dated 11/13/2018 E12-03-042, Environmental Surveillance, Version 3.0 E17-03-001, Licensed Packagings/Regulated Waste Packaging Work Practice, Version 8 MCP-30036, Respiratory Protection Program, Version 17.0 MCP-30102, Radiological Respiratory Protection Program, Version 9.0 MCP-30104, Personal External Dosimetry Program, Version 13.0 MCP-30105, Bioassay Program. Version 14.0 MCP-30108, ALARA Program, Version 8.0 MCP-30109, Internal Dose Tracking System, Version 8.0 3

MCP-30112, Current Shipping Container Information, Version 24 MCP-30121, Review and Reporting of Liquide Effluent Monitoring Results, Version 5.2 MCP-30222, SP-1 Configuration and Packaging SP1/SP2/SP3 Shipping Containers, Version 4.1 SOP-40020, In-Plant Air Sampling, Version 18.0 SOP-40031, Waste Effluent Monitoring & Sampling, Version. 14.0 SOP-40032, Radioactive Gaseous Effluent Sampling, Version 24.0 SOP-40033, Environmental Thermoluminescence Dosimetry, Version 1.0 SOP-40034, Surface Soil Sampling, Version 8.1 SOP-40035, Forage Sampling, Version 8.0 SOP-40039, Richland WWTF Sludge Sampling, Version 8.0 SOP-40042, Routine Fenceline/Building Exterior Radiation Level Surveys, Version 7.0 SOP-40058, Posting Requirements, Version 5.1 SOP-40059, Radiation Job Permit, Version 8.0 SOP-40065, Nuclear Materials Shipping and Receiving- General Rules, Version 22 SOP-40071, Radioactive Package Marking and Labeling, Version 26 SOP-40072, Shipping Container Maintenance and Re-work, Version 26 SOP-40082, Coplanarity Inspection of BWR Shipping Packages, Versions 4.1 SOP-40083, Shipping and Receiving of UO2 Fuel Assemblies in SP-1/SP-2/SP-3 Shipping Containers, Version 15.1 SOP-40174, General Facility Radiation Work Procedure, Version 25.0 SOP-40198, Respiratory Protection, Version 12.0 SOP-40409, Packaging Fuel Bundles for Shipment in Shipping Container SP-1, SP-2, SP-3, and TNB-1, Version 10 SOP-40611, ICP-MS Analysis of Miscellaneous Samples, Version 3.1 SOP-40937, Shipping and Receiving of MAP-12 Shipping Containers, Version 6.1 SWI-40083A, Station 1 Outer Container Inspections, Version 8.1 SWI-40083B, Station 1 Inner Container Inspections SWI-40083D, Station 2 Inner Container Inspections SWI-40083F, Station 3 Outer Container Inspections Condition Reports Written as a Result of the Inspection:

2019-1074 Condition Reports Reviewed:

2019-850, 2019-799, 2019-735, 2019-720, 2019-588, 2019-552, 2019-520, 2019-324, 2019-1141, 2018-9724, 2018-8598, 2018-8010, 2018-6502, 2018-6350, 2018-6344, 2018-5293, 2018-5263, 2018-4617 Other Documents:

2018 and 2019 Dose Tracking Data Chapter 2 of the License Application: Organization and Administration Chapter 9 of the License Application: Environmental Protection Inspection Report -

Chapter 11 of the License Application: Management Measures Framatome Emission Units (list of processes that emit to a specific stack)

Framatome Inc. Controller Information Scenario Messages Instruction Packet for Ed Foster Instruction Packet for Heather Huston and Liz Temple (KADLEC Evaluators)

Instruction Packet for Kirk Westerfield 4

Instruction Packet for Scott Franz Legacy document - Licensing Conditions, Rev. 47, page 2-8, November 10, 2005 shows Radiation Protection function performs quarterly ENV inspections Legacy document - Technical Assistance Request - Siemens Power Corporation (SPC) 10 CFR 20.2003 Exempt Request, October 24, 1994 (signed by Robert C.

Pierson, NRC)

Moulage Application and Instruction Notes Organizational Chart of the EHS&L group P&IDs: CSA-611900; Nitrogen System; Rev. 12, 15, & 6; 3/16, 6/16, & 3/17 CSA-611005; UF6 Cylinder Recertification Facility; Rev. 13, 2/18 PERMT/PERT Field Exercise Planned for Wednesday April 24th, 2019 Physical Security Plan Quality Control checks for analytic equipment for uranium analysis:

Method 674 - U-235, ICMPS Method 675 - Low Level Uranium (LLU), ICMPS Radiation Protection and Environmental Protection - Richland HRR site - 15th to 18th May 2018, dated June 13, 2018

5. ACRONYMS AND INITIALISMS ADAMS NRCs document system ALARA As Low As Reasonably Achievable ARF Ammonia Recovery Facility CAP Corrective Action Program CFR Code of Federal Regulations COC Certificate of Compliance CR Condition Report CY Calendar Year DOT Department of Transportation EAL(s) Emergency Action Level(s)

EOC Emergency Operations Center EPA Environmental Protection Agency EPIP(s) Emergency Plan Operating Procedure(s)

E-Plan Emergency Plan HST Health and Safety Technician IC Incident Commander ICMPS Inductively Coupled Plasma Mass Spectrometer IP Inspection Procedure LA License Application LIMS Laboratory Information Management System LLU Low Level Uranium MCP Management Control Procedure NFI Nuclear Fuel Industries NMSS Nuclear Material Safety and Safeguards NRC Nuclear Regulatory Commission NVLAP National Voluntary Laboratory Accreditation Program P&ID Piping and Instrumentation Diagram 5

PAR(s) Protective Action Recommendation(s)

PED Plant Emergency Director PEMS Plant Effluent Monitoring System (i.e., the lift station)

PERMT Plant Emergency Response Management Team PERT Plant Emergency Response Team RII Region II (Region 2)

Rev. Revision RP Radiation Protection SAP Software Application Program SF Specialty Fuels SOP Standard Operating Procedure SPC Siemens Power Corporation SWI Standard Work Instruction UF6 Uranium Hexafluoride TN-A Trans Nuclear Americas UO2 Uranium Dioxide WWTF Waste Water Treatment Facility (which is the Ammonia Recovery Facility) 6