ML22207B230

BWXT Nuclear Operations Group, Inc. - Lynchburg - Integrated Inspection Report 07000027/2022002

ML22207B230
Person / Time
Site:	BWX Technologies
Issue date:	07/26/2022
From:	Eric Michel NRC/RGN-II/DFFI
To:	Bittner J BWXT
References
IR 2022002
Download: ML22207B230 (28)

Text

July 26, 2022 Mr. James J. Bittner Vice President and General Manager BWXT Nuclear Operations Group, Inc.

P.O. Box 785 Lynchburg, VA 24505-0785

SUBJECT:

BWXT NUCLEAR OPERATIONS GROUP, INC. - LYNCHBURG -

INTEGRATED INSPECTION REPORT 07000027/2022002

Dear Mr. Bittner:

On June 30, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at BWXT Nuclear Operations Group, Inc. - Lynchburg. On July 14, 2022, the NRC inspectors discussed the results of this inspection with Mr. Rich Freudenberger and other members of your staff. The results of this inspection are documented in the enclosed report.

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

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Signed by Michel, Eric on 07/26/22 Eric C. Michel, Chief Projects Branch 2 Division of Fuel Facility Inspection Docket No. 07000027 License No. SNM-42

Enclosure:

As stated cc w/ encl: Distribution via LISTSERV

ML22207B230 X Non-Sensitive X Publicly Available X SUNSI Review Sensitive Non-Publicly Available OFFICE RII/DRP RII/DFFI RII/DFFI RII/DFFI RII/DFFI RII/DFFI RII/DFFI RII/DFFI RII/DFFI NAME A. Alen T. Sippel P. Startz N. Peterka L. Pitts G. Goff C. Taylor N. Pitoniak E. Michel DATE 07/22/22 07/20/22 07/21/22 07/22/22 07/22/22 07/21/22 07/22/22 07/21/22 07/26/22 U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number: 07000027 License Number: SNM-42 Report Number: 07000027/2022002 Enterprise Identifier: I-2022-002-0058 Licensee: BWXT Nuclear Operations Group, Inc.

Facility: BWXT Nuclear Operations Group, Inc. - Lynchburg Location: Lynchburg, VA 24505 Inspection Dates: April 1, 2022 to June 30, 2022 Inspectors: A. Alen, Senior Resident Inspector G. Goff, Fuel Facility Inspector N. Peterka, Fuel Facility Inspector N. Pitoniak, Senior Fuel Facility Inspector L. Pitts, Senior Fuel Facility Inspector P. Startz, Fuel Facility Inspector T. Sippel, Senior Fuel Facility Inspector C. Taylor, Senior Fuel Facility Inspector 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 an integrated inspection at BWXT Nuclear Operations Group, Inc. -

Lynchburg, in accordance with the fuel cycle facility inspection program. This is the NRCs program for overseeing the safe operation of licensed fuel cycle facilities. Refer to https://www.nrc.gov/materials/fuel-cycle-fac.html for more information.

List of Violations No violations of more than minor significance were identified.

Additional Tracking Items None.

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PLANT STATUS During the inspection period routine fuel manufacturing operations and maintenance activities were conducted in the fuel processing areas, the uranium recovery (UR) facility, and the research and test reactors (RTR) facility.

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 IP 88020 - Operational Safety The inspectors evaluated selected aspects of the licensees operational safety program to verify compliance with selected portions of Title 10 of the Code of Federal Regulations (CFR) 70, "Domestic Licensing of Special Nuclear Material," including 70.61, 70.62, and Chapter 11, Management Measures, of the facilitys license application, and applicable licensee procedures.

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

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

process areas and selected accident sequences in safety analysis reports (SARs) 15.8, 15.21, 15.27, 15.28, 15.36, and 15.40 Review of Safety Controls and Related Programs (IP Section 02.02)

The inspectors reviewed information related to administrative, engineered, and passive safety controls or items relied on for safety (IROFS) for the accident sequences selected above, including the identification of the licensees assumptions and bounding cases as they apply to each of the selected accident sequences, safety controls, or IROFS. This review was performed to verify that the controls or IROFS were available and reliable to perform their intended safety functions and that the design basis assumptions were reflected in the 3

actual conditions in the field. The specific safety controls selected for review are listed below:

material specification IROFS for specific use items for furnace 4 listed in SAR section 15.27.4.1.1, "Criticality Safety Parameters and Limits, Controls, and Control Maintenance" piece-count IROFS limits item numbers per location for furnace 4 listed in SAR section 15.27.4.1.1 piece-count IROFS limits maximum items per a fixture for furnace 4 listed in SAR section 15.27.4.1.1 spacing requirements for furnace 4 use listed in SAR section 15.27.4.1.1 material specification IROFS for specific use items in furnace 3 listed in SAR section 15.27.4.1.1 piece-count IROFS limits item numbers per location for furnace 3 listed in SAR section 15.27.4.1.1 piece-count IROFS limits maximum items per a fixture for furnace 3 listed in SAR section 15.27.4.1.1 spacing requirements for furnace 3 use listed in SAR section 15.27.4.1.1 geometry requirements for furnace 3 listed in SAR section 15.27.4.1.1 conducted walkdowns of waste drum storage areas to verify compliance with stacking and spacing requirements of EP-726, "Drum Storage," Revision (Rev.) 1 Implementation of Safety Controls (IP Section 02.03)

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

reviewed the functional test record PM40102, programmable logic controller (PLC) over temperature, conducted on September 9, 2021; which evaluated the functional performance of the temperature limit IROFS for furnace 4 listed in SAR section 15.27.4.1.1 inspected racks that use piece-count controls on the maximum items per each fixture and the maximum items per location, to verify that their configuration is in accordance with the requirements for furnace 4 listed in SAR section 15.27.4.1.1 inspected racks that use piece-count controls on the maximum items per each fixture and the maximum items per location, to verify that their configuration is in accordance with the requirements for furnace 4 listed in SAR section 15.27.4.1.1 observed wastewater treatment plant operations and interviewed one supervisor and one operator conducted a walkdown of the Lynchburg Technology Center (LTC),

interviewed two supervisors, and reviewed NCS postings NCS-2004-272 and 15-40-004 4

conducted a walkdown of wastewater treatment plant inline monitor piping to verify proper valve positions and controls Safety Control Support Programs (IP Section 02.04)

The inspectors assessed additional management measures that support the availability and reliability of the selected safety controls to verify these were implemented in accordance with 10 CFR 70 and applicable sections of the license application. Specifically, the inspectors conducted the following:

walked down an active engineered IROFS, portions of the backup power supply for the UR scrubber, comparing it to drawing 14AE7_1000 E, "Bay 14A Scrubber/Power Distribution Block Diagram;" the IROFS provides backup power to the bay 14A scrubber reviewed N-130 CR 1035778, SER 19-009 Phase 1, "Delivery, Installation, Surrogate Qualification Test Runs, and Data Evaluation," included functional specification for PLC operational requirements concerning furnace operations conducted walkdowns of retention tanks, reviewed inline monitor sources 00001, 076476, 076472, and 076471, and reviewed RP-07-079 Form 4, "Inline Monitor Weekly Reference Checks," Rev. 9; and RP-07-079, "Calibration and Operation of the Canberra Inline Liquid Waste Monitors,"

Rev. 8 reviewed corrective action program (CAP) entries/documents for area process affecting IROFS (see document list) reviewed IA-SAR-2021-11-01, "Internal Audit Summary Report," dated December 2021 observed weekly diesel generator surveillance for generator 013 and weekly inspection reviewed samples of training records for furnaces 1, 2, 3 and 4; training documents included TP-HT-0005, Rev. 4, completed for five equipment operators in 2021 IP 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 (where applicable). 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 reviewed the following fire protection features and licensee activities in UR and the container storage building, as well as bay 17 (vault 7), bays 6A -10A, and the railcar storage building:

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fire detection equipment, fire suppression equipment, fire alarms, piping, and manual fire-fighting equipment in the areas the handling and storage of transient combustibles fire safety cabinets for storage of flammable liquids and flammable gases control of ignition sources fire walls, fire doors, and fire dampers Preventative Controls (IP Section 02.02)

The inspectors interviewed licensee staff, reviewed documentation, and conducted plant walkdowns 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:

walkdowns in UR and the container storage building to verify control of combustible sources such as metal fines such as zircoloy, cleaning rags, wood crates, and paper packaging materials walkdowns in UR and the container storage building to verify control of ignition sources and observe any work being conducted under a hot work permit observed the usage of fire safety cabinets for the storage of flammable and combustible liquids and gases and that these cabinets were grounded and vented reviewed HS-03-02, "Fire Prevention," Rev. 8 reviewed HS-03-03, "Ignition Source Permits," Rev. 21.0 reviewed HS-03-04, "Electrical Appliance Control," Rev. 11.0 Fire and Gas Detection and Alarm Systems (IP Section 02.03)

The inspectors reviewed selected fire or gas detection devices to verify that detection and alarm systems were able to detect the minimal fire within the required time and initiate the safety function credited in the license application, or the ISA summary. Specifically, the inspectors conducted the inspection activities listed below:

walked down the smoke detectors and alarm pull stations and associated strobes/horns in the container storage building for physical damage, blockage, or potential interference that could affect functionality walked down the smoke detectors, heat detectors, and alarm pull stations, and associated strobes/horns in UR for physical damage, blockage, or potential interference that could affect functionality observed the secondary alarm station to verify visual and audible alarms would be received at a staffed location if a detection system actuated conducted interviews with fire safety personnel to determine whether fire detection panels and equipment receive electrical power from a primary source and a backup source reviewed operability evaluations (June/July 2021) for smoke detectors, heat detectors, and alarm pull stations and associated strobes/horns reviewed HS-FP-017, "Inspection, Test & Maintenance of Fire Alarm System,"

Rev. 11.0 6

Suppression Systems and Activities (IP Section 02.04)

The inspectors interviewed licensee staff, reviewed fire protection program documents, and conducted plant walkdowns to verify that suppression systems were capable of performing the safety function credited in the license application (section 7.5.1). Specifically, the inspectors:

walked down the in-rack sprinklers and the building sprinklers in the container storage building for physical damage or potential interference that could affect functionality walked down the building sprinklers in UR for physical damage or potential interference that could affect functionality observed the pressure indication and position of the water supply control valves for the container storage building and UR observed fire extinguishers for the type of fire extinguishing agent, gauge setting, placement in designated locations, indications of nozzle impairment or hose deterioration, and accessibility observed that dry powder (extinguishing agent) and scoops were in the designated areas observed that the secondary alarm station would receive audible/visual indication if an automatic suppression system had been activated observed fire hydrants and fire hose hook-ups for indications of impairment and accessibility reviewed pressure/flow calculations for activation of sprinkler systems in the container storage building and UR reviewed HS-FP-006, "Portable Fire Extinguisher Inspection," Rev. 13, and operability evaluations (performed in 2022) for fire extinguishers located in UR and the container storage building reviewed HS-FP-008, "Sprinkler System, Standpipes and Control Valve Inspection, Test, & Maintenance," Rev. 21; results from a first quarter (2022) sprinkler flow alarm; and operability evaluations (performed in 2022) for sprinklers located in UR and the container storage building reviewed HS-FP-016, "Annual Service Testing of Fire Hose," Rev. 10.0 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 ISA summary.

Specifically, the inspectors:

interviewed staff regarding fire doors, fire walls, and fire dampers walked down IROFS passive fire protection features in vault 7 including the condition of fire walls, fire dampers, and the fire door's self-closing and latching features observed fire door testing (non-IROFS) in bays 6A - 10A, and resulting corrective action entries and fire safety impairments (as applicable) reviewed a first quarter 2022 operability evaluation for UR fire barriers (fire doors and fire walls) reviewed HS-FP-018, "Fire Barrier/Fire Damper Inspection," Rev. 11.0 7

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 completed the following activities:

observed fire brigade training during a live fire scenario during the April 2022 emergency preparedness exercise (see section IP 88051 - Evaluation of Exercises and Drills) observed functional testing of emergency lighting and exit signs walked down two fire engines at fire station 1 (the on-site fire station) to verify that the fire engines had the required fire-fighting equipment as per the checklists reviewed the pre-fire plan for UR and the container storage building reviewed HS-03-10-01, "Fire Protection Impairment Report 007," dated June 9, 2022 reviewed fire pump removal package from 2016 which documented the safety evaluation for this change modification reviewed the piping & instrumentation drawing (P&ID) for the sprinkler plan for bay 14A dated December 13, 2019 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 and interviewed the staff regarding the following CAP entries, audits, and self-assessments:

Corrective Actions Entries:

o CA202101116 o CA202101208 o CA202101235 o CA202101323 o CA202101478 o CA202101575 o CA202200611 Audits:

o Quarterly Fire Safety Audit Summary Report - 2nd Quarter - 2021 dated June 18, 2021 o Quarterly Fire Safety Audit Summary Report - 3rd Quarter - 2021 dated September 24, 2021 o Quarterly Fire Safety Audit Summary Report - 4th Quarter - 2021 dated November 30, 2021 o Quarterly Fire Safety Audit Summary Report - 1st Quarter - 2022 dated March 25, 2022 Work Orders:

o Form N-350, Bay 14A Stairwell Fire Doors, dated June 16, 2022 o Form N-350, Bay 9A and 10A Stairwell Fire Doors, dated June 16, 2022 8

IP 88135.02 - Plant Status The inspectors routinely conducted walkdowns of licensee areas, observed operators, material control and accounting and security force personnel, inspected postings and licensee guidance documents, interviewed plant personnel, and discussed the results of operational and shift turnover meetings to gain insight into the status of facility activities, risk-inform the selection and implementation of the appropriate core inspection procedures, and ensure compliance with license and regulatory requirements.

Plant Tours (IP Section 03.01)

The inspectors performed weekly tours of plant operating areas housing special nuclear material (SNM) to verify that licensed activities were conducted safely and in compliance with the license and 10 CFR 70.

including walkdowns of the waste line above the retention tank building following repairs Status Meetings (IP Section 03.02)

The inspectors, on a routine basis, attended and reviewed the results of scheduled licensee meetings to determine plant status and awareness of site activities so that inspection resources were appropriately focused on those activities with the higher safety significance.

Record and Log Reviews (IP Section 03.03)

The inspectors reviewed selected records and logs to assure they were developed, maintained, and reported as required by applicable license and regulatory requirements.

Identification and Resolution of Problems (IP Section 03.05)

The inspectors reviewed selected issues to determine if the licensee was entering equipment, human performance, and other performance issues in a formalized program to identify, track, and assure correction of safety and safeguard significant problems in accordance with 10 CFR 70.62(a)(3) and applicable license requirements.

CA 2021-1568, encapsulated fuel components inadvertently cut (i.e.,

breached) in non-fuel operation on November 4, 2021 CA 2022-0070, SNM not properly logged for UR blend box mass/moderator smart form (NCS control), report date April 13, 2022 CA 2022-0509, administrative control IROFS involving pressure instruments in UR not subject to routine maintenance controls, report date April 27, 2022 CA 2022-0402, leak identified in pipe culvert upstream of the retention building, report date May 2, 2022 9

Event Review (IP Section 03.06)

The inspectors reviewed the plant events listed below to determine if the event warranted the use of formal event review criteria and to evaluate the licensees response was in accordance with 10 CFR Parts 40.60 (source material), 70.50 (mainly radiological events),

70.52 (criticality and safeguards events), 71.95 (transportation events), 73.71 (safeguards events), 20.2201, 20.2202, and 20.2203 (radiological and environmental events):

CA 2022-0501, lower explosive level detector outside of UR high-level dissolvers failed calibration on April 11, 2022 CA 2022-0586, specialty fuel facility (SFF) exterior flammable gas piping inadvertently breached during maintenance activity on April 28, 2022 Audits (IP Section 03.07)

The inspectors reviewed the internal and/or external audit listed below to determine whether it has been performed in accordance with 10 CFR 70.22(h)(1) and the license application:

L121521_BWXT_111_Rev. 1, March 29, 2022 Radiation Work Permit (RWP) (IP Section 03.09)

The inspectors reviewed and observed the RWPs listed below to determine whether the RWP contains the information required by Chapter 4, Radiation Safety, of the license application, the Radiation Protection Manual, and implementing procedures:

RWP 21-0058, "General Maintenance in Bays 12A, 13A, 14A, and 15A for Industrial Engineering and Contractor Personnel," located in UR and conducted on June 23, 2022 RWP 22-0002, "Equipment Removal in Downblend," located in UR and conducted on June 23, 2022 88135.04 - Resident Inspection Program Operational Safety The inspectors evaluated whether the material condition and as-found configuration of selected site structures, systems, and components, documentation, personnel, and IROFS to verify compliance with 10 CFR 70, the license, the SAR and/or license application, and licensee policies and procedures; and determine whether they are appropriate, available, and reliable to protect worker and public safety during normal, off-normal, and accident conditions.

Operations Safety Walkdown (IP Section 03.01)

The inspectors evaluated the operational safety of the systems, sub-systems, and/or processes listed below associated with SAR 15.12, "Liquid and Solid Waste Handling Processes in Uranium Recovery," Rev. 85:

Liquid Waste Handling Processes o raffinate/condensate waste solutions o raffinate waste collection system 10

o inline monitors 1, 2, and 3 o annular waste and organic tanks Solid Waste Handling Processes o liming enclosure o < 2.5-liter container counting station o transient/floor stored < 2.5-liter containers o < 2.5-liter container racks IP 88135.05 - Resident Inspection Program Fire Protection (Annual/Quarterly)

The inspectors evaluated the operational status and material condition of fire protection systems, structures, and components to verify compliance with the fire protection program as described in Chapter 7, Fire Safety, of the license application as required.

Fire Area Walkdown (IP Section 03.01)

The inspectors walked down and evaluated the fire areas listed below:

bays 4A, 5A, 6A, 7A, 8A, 9A, and 10A the waste operations field area and compactor IP 88135.19 - Post Maintenance Testing The inspectors evaluated post-maintenance test activities to verify compliance with license application Chapter 11, Management Measures, and test procedures and/or work order (WO) instructions to confirm functional capability of the IROFS and/or safety control following maintenance.

Post-Maintenance Testing (IP Section 03.01)

The inspectors reviewed the post-maintenance test listed below. Tests were either observed directly or test results were reviewed.

logic and calibration testing (RP-07-103 Form 2 and RP-07-104 Forms 1 and

2) of new criticality safety system detectors (17, 28, and 39) covering the expanded TRi-structural ISOtropic (TRISO) fuel processing area; test conducted on May 22, 2022 IP 88135.22 - Surveillance Testing The inspectors evaluated IROFS and safety controls that required periodic surveillance and/or calibration tests to ensure they were available and reliable to perform their function when needed, to comply with license application Chapter 11, Management Measures, and the performance requirements of 10 CFR 70.61 and 70.62, and to maintain their operational readiness consistent with the ISA.

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Surveillance and Calibration Testing (IP Section 03.01)

The inspectors reviewed the surveillance and/or calibration tests listed below. Tests were either observed directly or test results were reviewed.

E61-023 and E61-044, Inline Monitor Operation Checks, Daily, and Shiftly (respectively), conducted May 17, 2022 FACILITY SUPPORT IP 88051 - Evaluation of Exercises and Drills The inspectors observed and evaluated the licensees graded biennial exercise conducted on April 13, 2022, as well as briefings and critiques involving both on-site and off-site participants, to verify compliance with 10 CFR 70.22(i)(3)(xii), and the emergency plan. The scenario included a tornado striking and damaging the facility which resulted in the dispersal of radioactive material, a propane fire, an acid spill, a fatality, and contaminated and injured victims.

Exercise Planning (IP Section 02.01)

The inspectors reviewed the emergency exercise scenario and discussed the exercise objectives with licensee personnel to verify compliance with the emergency plan, emergency plan implementing procedures, and 10 CFR 70.22(i)(3)(xii). The inspectors reviewed the following:

the frequency of and scenarios for exercises conducted by the licensee over the past 2 years including the licensee's basis for crediting actual emergency response organization (ERO) activations as drills/training the exercise scenario as it related to testing all elements of the emergency plan and its use of the postulated incident scenarios in section 5.0 of the emergency plan the pre-staging of equipment in preparation for the exercise on the day before the drill the duties and responsibilities of exercise personnel including controllers and evaluators the confidentiality of the scenario and objectives Exercise Execution and Emergency Plan Implementation (IP Section 02.02)

The inspectors observed the initiation of the emergency exercise, the activation of the emergency operations center (EOC) and ERO to verify compliance with the emergency plan, emergency plan implementing procedures, and 10 CFR 70.22(i)(3)(xii). The inspectors reviewed or observed the following:

the licensees analysis of plant conditions including assessment and classification of the accident scenario staffing for all EOC/emergency organization positions on-site communication to occupational workers as it related to protective action recommendations 12

the simulated process to conduct personnel accountability drafting of off-site notifications including a review of content and time of issuance press release approval and issuance emergency director command and control of the EOC dose assessor use of radiation survey results and environmental monitoring results during assessment of the accident scenario response coordinators recommendations regarding conditions for terminating the event and restarting normal operations recovery and re-entry recommendations implemented by the EOC/emergency organization the calibration dates of selected survey meters and electronic dosimeters used in the drill the establishment of the decontamination zone with yellow and magenta tape and signs at the scene members of the licensees emergency team assembly at designated assembly areas and the arrival of off-site emergency responders including firefighters and emergency medical technicians emergency response teams actions, including search and rescue activities for casualties, assessment of the affected area, deployment and use of fire-fighting equipment, on-scene medical treatment, HazMat activities, medical treatment and decontamination during the ambulance ride and triage in the emergency room the radiological zone at the hospital emergency room drop-off and in the emergency room that medical and radiological staff gave priority to the severity of the medical injuries versus decontamination of the victim response to emerging situations to address the exercise scenario and meet the exercise objectives the incident commander's command and control of the emergency response team and coordination of actions with off-site emergency responders extinguishing a live fire scenario with the proper personal protective equipment and fire-fighting equipment, entry into and search of a possible fire area for victims (see section IP 88055 - Fire Protection above in reference to training)

Critiques, Exercise Control, and Identification and Resolution of Problems (IP Section 02.03)

The inspectors observed the staff critique of the emergency exercise and reviewed the licensees related CAP entries to verify compliance with the emergency plan, emergency plan implementing procedures, and 10 CFR 70.22(i)(3)(xii). The inspectors reviewed or observed the following:

critiques conducted by the licensee with ERO members and off-site participants documented deficiencies identified during critique including items entered into the licensees CAP discussion regarding whether drill objectives were satisfied 13

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

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

On April 13, 2022, the inspectors presented the emergency preparedness exercise inspection results to James J. Bittner and other members of the licensee staff.

On April 21, 2022, the inspectors presented the operational safety inspection results to Rich Freudenberger and other members of the licensee staff.

On June 16, 2022, the inspectors presented the fire protection inspection results to James J. Bittner and other members of the licensee staff.

On July 14, 2022, the inspectors presented the integrated inspection results to Rich Freudenberger and other members of the licensee staff.

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DOCUMENTS REVIEWED Inspection Type Designation Description or Title Revision or Procedure Date 88020 Corrective Action 2019-1588 Corrective Action Various Documents 88020 Corrective Action 2022-0402 Corrective Action Documents Various Documents 2022-0365 2022-0317 2022-0289 2022-0237 2022-0195 2022-0140 2022-0059 2022-0029 2022-0025 2022-0010 2021-1687 2021-1643 2021-1575 2021-1572 2021-1568 2021-1561 2021-1555 COM-93226 88020 Drawings LP4129E Plant and Recovery Hot Waste Monitoring System Rev. 2 88020 Drawings WTRT-6000 BWXT Waste Treatment Retention Tank Area 05/05/2018 88020 Engineering ECR 20190575 Lab 110B Separator Various Changes 88020 Engineering ECR 20200102 300-04 and 300-05 Setpoint Change Changes 88020 Engineering ECR 20200265 WWTP PCV Equivalency Various Evaluations 88020 Miscellaneous NCS-2021-107 Justification for Continued Operations of Chemistry 11/15/2019 JCO Laboratory Liquid Waste System Inline Monitor System 88020 Procedures EP-726 Drum Storage Rev. 1 15

Inspection Type Designation Description or Title Revision or Procedure Date 88020 Procedures QWI 02.1.02 Preparation and Maintenance of Safety Analysis Reports Rev. 19 88020 Procedures QWI 02.1.03 Integrated Safety Analysis Methodology Rev. 18 88020 Procedures QWI 05.1.47 Electronic Record Retention for ESH&S Rev. 01 88020 Procedures QWI 14.1.01 Preventative/Corrective Action System Rev. 42 88020 Procedures QWI 17.1.02 Internal Quality Audits Rev. 23 88020 Procedures QWI 17.1.1 Environment, Safety, Health, & Safeguards Audit Program Rev. 13 88020 Procedures QWI 18.1.1 Safety Training Rev. 12 88020 Procedures QWI 18.1.11 Required Training Program Rev. 2 88020 Procedures QWI 18.1.3 On-The-Job Training (OJT) Rev. 8 88020 Procedures QWI 2.2.17 Suspending and Restarting Fuel Operations Rev. 4 88020 Procedures QWI 5.1.12 Change Management Rev. 37 88020 Procedures QWI 5.1.20 Change Review Board Rev. 11 88020 Procedures QWI 5.1.4 Operating Procedures Rev. 25 88020 Procedures QWI 5.1.7 Safety Evaluation Requests Rev. 37 88020 Procedures QWI 6.1.14 Procuring or Fabricating Manufacturing or Inspection Rev. 7 Equipment 88020 Procedures QWI 9.1.7 Preventative/Predictive Maintenance and Safety-Related Rev. 12 Controls Testing Program 88020 Procedures RP-07-079 Calibration and Operation of the Canberra Inline Liquid Rev. 8 Waste Monitors 88020 Procedures RP-07-57 Instrument Service Log Rev. 24 88020 Self-Assessments IA-SAR-2021 Internal Audit Summary Report 12/01/2021 01 88051 Drawings EOC_1004 Initial Emergency Assessment Flow Chart Rev. 43 88051 Miscellaneous BWXT Nuclear Operations Group-Lynchburg Emergency Rev. 34 Plan 88051 Miscellaneous Emergency Exercise Biennial Drill Information 88051 Miscellaneous 2nd Quarter 2021 COVID-19 Compensatory Tabletop Drill Package 88051 Miscellaneous Emergency Organization Quarterly Exercise, 4th Quarter -

2021 88051 Miscellaneous 2022 Biennial Drill, Drill Simulation & Safety Briefings 88051 Miscellaneous Drill Coordinators/Evaluators Training 2022 Biennial Drill 16

Inspection Type Designation Description or Title Revision or Procedure Date 88051 Miscellaneous Emergency Management/Response Organization Biennial Drill Critique Slides 88051 Miscellaneous 1st Quarter 2022 Tabletop Drill slides 88051 Miscellaneous HS-2021-031 1st Quarter 2021 Emergency Drills 03/11/2021 88051 Miscellaneous HS-2022-010 4th Quarter 2021 Emergency Drills 01/24/2022 88051 Miscellaneous HS-2022-011 3rd Quarter 2021 Emergency Drill 01/24/2022 88051 Miscellaneous HS-2022-012 2021 Security Emergency Director 3rd & 4th Quarter 01/24/2022 Training 88051 Procedures EPR-01-02 Activation of the Emergency Organization by an Rev. 10 Unannounced Sounding of the Emergency Team Assembly Alarm 88051 Procedures EPR-02-01 Initial Emergency Incident Assessment Rev. 10 88051 Procedures EPR-02-07 Emergency Shutdown of Facility Rev. 6 88051 Procedures EPR-03-02 Industrial Health & Safety Response to Fire/Explosion Rev. 9 88051 Procedures EPR-03-03 Emergency Procedure for a Fire/Explosion Involving Rev. 10 Radioactive Material 88051 Procedures EPR-03-07 Response to Severe Weather Rev. 22 88051 Procedures EPR-03-12 Decontamination of Personnel During Hazmat Response Rev. 7 88051 Procedures EPR-03-13 Hazardous Material Release Notification Rev. 14 88051 Procedures EPR-03-14 Radiological Assessment for Incidents Involving Radioactive Rev. 7 Material 88051 Procedures EPR-03-17 Radiological Environmental Sampling in an Emergency Rev. 16 88051 Procedures EPR-03-19 Estimation of Off-Site Dose from a Release of Radioactive Rev. 13 Material 88051 Procedures EPR-06-04 Emergency Drills Rev. 19 88055 Calculations Uranium recovery sprinkler calculations 01/22/2020 88055 Corrective Action CA202101116 08/04/2021 Documents 88055 Corrective Action CA202101208 08/25/2021 Documents 88055 Corrective Action CA202101235 08/27/2021 Documents 88055 Corrective Action CA202101323 09/15/2021 Documents 17

Inspection Type Designation Description or Title Revision or Procedure Date 88055 Corrective Action CA202101478 10/20/2021 Documents 88055 Corrective Action CA202101575 11/05/2021 Documents 88055 Corrective Action CA202200611 05/04/2022 Documents 88055 Corrective Action CA202200810 06/14/2022 Documents Resulting from Inspection 88055 Corrective Action CA202200820 06/15/2022 Documents Resulting from Inspection 88055 Corrective Action CA202200821 06/15/2022 Documents Resulting from Inspection 88055 Corrective Action CA202200822 06/15/2022 Documents Resulting from Inspection 88055 Corrective Action CA202200824 06/15/2022 Documents Resulting from Inspection 88055 Corrective Action CA202200825 06/15/2022 Documents Resulting from Inspection 88055 Corrective Action CA202200826 06/15/2022 Documents Resulting from Inspection 18

Inspection Type Designation Description or Title Revision or Procedure Date 88055 Corrective Action CA202200827 06/15/2022 Documents Resulting from Inspection 88055 Drawings BWXT-resub Sprinkler Plan - Building 14A 12/13/2019 28-2-2013.dwg 88055 Engineering NCS-PA Nuclear Criticality Safety Evaluation for 235R001 Shipping 06/23/2021 Evaluations 00001 Container Storage and Handling in Core Assembly, the Container Storage Facility, and the Railyard Storage Building 88055 Fire Plans Pre-Fire Plan 88055 Miscellaneous Print-Out of Completed Fire Impairments 88055 Miscellaneous Approximate Hydrant Locations, Water Line Sizes, & Flows 88055 Miscellaneous Printed slide training presentation for fire department connections and standpipe connections 88055 Miscellaneous AGF Vendor's Test Valve Information Manufacturing Inc.

88055 Miscellaneous Facility Siting Fire Safety Analysis Section and Chapter on Locations of 01/19/2022 Review (FSR) Focus: Bays 12A, 13A, 14A, 15A and 08/14/2018 88055 Miscellaneous Fire Pump Industrial Health and Safety Technical Work Record - HS-Removal Package 2012-036 - 01/17/2013 Industrial Health and Safety Technical Work Record - HS-2016-076 - 07/07/2016 Fire Pump Removal Safety Evaluation Report (SER)

Change Management document - CHG-00000947 -

07/18/2016 Before and after diagrams 88055 Miscellaneous HS-03-10-01 Fire Protection Impairment Report 007 06/09/2022 88055 Miscellaneous HS-ET-003 - Inventory of Red Truck Rev. 13 Attachment 2 88055 Miscellaneous HS-ET-003 - Inventory of White Truck (Engine 18-1) Rev. 13 Attachment 3 19

Inspection Type Designation Description or Title Revision or Procedure Date 88055 Miscellaneous SARs 15.05, 15.06, 15.07, 15.09, 15.12, 15.13, 15.14, 15.25, 15.33, 15.42 88055 Operability Container Storage Building - Emergency Lights, Fire Main 05/13-Evaluations Valves, Fire Extinguishers, Sprinkler Risers, Fire Hydrants, 26/2022 Exit Signs 88055 Operability Uranium Recovery - Emergency Lights, Fire Extinguishers, 05/04-Evaluations Sprinkler Risers, Bull Horn, Exit Signs 25/2022 88055 Operability 2021 Uranium Recovery - Smoke Detectors, Fire Alarm Pull June/July Evaluations Stations, Notification Horns/Strobes, Heat Detectors 2021 88055 Operability 2021 Container Storage Building - Smoke Detectors, Fire 07/05-Evaluations Alarm Pull Stations, and Notification Horns/Strobes 07/2021 88055 Operability Uranium Recovery Fire Barriers (Fire Doors & Fire Walls) 01/14-Evaluations 17/2022 88055 Operability 1st Quarter Sprinkler Flow Alarm 03/12/2022 Evaluations 88055 Procedures Attachment to Preventive/Corrective Action System Rev. 18 QWI 14.1.01 88055 Procedures HS-03-02 Fire Prevention Rev. 8.0 88055 Procedures HS-03-03 Ignition Source Permits Rev. 21.0 88055 Procedures HS-03-04 Electrical Appliance Control Rev. 11.0 88055 Procedures HS-03-05 Control of Flammable and Combustible Liquids Rev. 9.0 88055 Procedures HS-03-06 Combustible Metals and Pyrophoric Materials Rev. 13.0 88055 Procedures HS-03-07 Control of Systems and Equipment for Fire Protection Rev. 5.0 88055 Procedures HS-03-08 Employee Fire Response and Firefighting Rev. 7.0 88055 Procedures HS-03-10 Control of Fire Protection System Impairments Rev. 18.0 88055 Procedures HS-FP-001 Monthly Inspection of Fire Hose Reels Rev. 10.0 88055 Procedures HS-FP-006 Portable Fire Extinguishers Inspection Rev. 13.0 88055 Procedures HS-FP-007 Fire Hydrant Testing and Maintenance Rev. 6.0 88055 Procedures HS-FP-008 Sprinkler System, Standpipes and Control Valve Inspection, Rev. 21.0 Test, & Maintenance 88055 Procedures HS-FP-009 Inspection of Fire Hydrants Rev. 8.0 88055 Procedures HS-FP-010 Monthly Inspection of Hose Houses Rev. 9.0 88055 Procedures HS-FP-015 Semi-Annual Inspections of Fixed Systems Rev. 8.0 20

Inspection Type Designation Description or Title Revision or Procedure Date 88055 Procedures HS-FP-016 Annual Service Testing of Fire Hose Rev. 10.0 88055 Procedures HS-FP-017 Inspection, Test, & Maintenance of Fire Alarm System Rev. 11.0 88055 Procedures HS-FP-018 Fire Barrier/Fire Damper Inspection Rev. 11.0 88055 Procedures HS-FP-020 5-Year Testing of the Water Loop Rev. 8.0 88055 Procedures OP-1041746 Operating Procedure for Storage of Material in the CSF Rev. 4 88055 Procedures QWI 02.1.03 Integrated Safety Analysis Methodology Rev. 18 88055 Self-Assessments Quarterly Fire Safety Audit Summary Report - 2nd Quarter - 06/18/2021 2021 88055 Self-Assessments Quarterly Fire Safety Audit Summary Report - 3rd Quarter - 09/24/2021 2021 88055 Self-Assessments Quarterly Fire Safety Audit Summary Report - 4th Quarter - 11/30/2021 2021 88055 Self-Assessments Quarterly Fire Safety Audit Summary Report - 1st Quarter - 03/25/2022 2022 88055 Work Orders Form N-350 Bay 14A Stairwell Fire Doors 06/16/2022 88055 Work Orders Form N-350 Bays 9A & 10A Stairwell Fire Doors 06/16/2022 88135.02 Corrective Action 2022-0070 SNM not properly logged for UR blend box mass/moderator 04/13/2022 Documents smart form (NCS control), incident 01/19/2022 88135.02 Corrective Action 2022-0402 Leak identified in pipe culvert upstream of the retention 05/02/2022 Documents building, incident 03/25/2022 88135.02 Corrective Action 2022-0534 Empty shipping containers shifted during transport 05/31/2022 Documents 88135.02 Corrective Action 2022-0594 Non-conformances identified with the tie-down band 05/02/2022 Documents hardware for the HFIR shipping container 88135.02 Corrective Action 2022-0408 Aluminum powder in RTRT 'hot' area not stored per SAR 05/06/2022 Documents 15.22 Resulting from Inspection 88135.02 Corrective Action 2022-0509 UR administrative control IROFS instrumentation not subject 04/27/2022 Documents to routine maintenance controls, incident 03/28/2022 Resulting from Inspection 88135.02 Corrective Action 2022-0620 Aluminum power storage racks not maintained readily 05/04/2022 Documents accessible 21

Inspection Type Designation Description or Title Revision or Procedure Date Resulting from Inspection 88135.02 Drawings M20978EL008E Shipping Container for Unirradiated Out/In HFIR Element Rev. C Details 88135.02 Engineering N-79 Evaluation of Unusual Incident - Lower-Explosive-Level 04/12/2022 Evaluations Detector outside of UPRR High-Level Dissolvers Failed Calibration 88135.02 Engineering N-79 Evaluation of Unusual Incident - Recovery Blend Box 02/02/2022 Evaluations Operators Identified Mass Log Errors 88135.02 Engineering NCS-2021-105 NCS Safety Concern for Encapsulated Fuel Cutting Event - 11/11/2021 Evaluations CA202101568 88135.02 Engineering NMCTWR 21-010 Evaluation of DOT Regulations and Reporting Requirements 11/09/2021 Evaluations Related to Encapsulated Fuel Cutting Saw Incident 88135.02 Miscellaneous Correspondence Letter to Dr. James M. Shuler, Manager, Department of 04/15/2022 Energy Packing Certification Program, Re: Authorization for Shipments of Fresh Fuel Using the Model No. Inner HFIR Unirradiated Fuel Element Shipping Container and Outer HFIR Unirradiated Fuel Element Shipping Container; from Yoira K. Diaz-Sanabria, Chief, Storage & Transportation Licensing Branch, Division of Fuel Management, Office of Nuclear Material Safety & Safeguards 88135.02 Miscellaneous Correspondence Memo to File from K. Conway, RP Unit Manager, Re: 11/09/2021 Incident Data 12A Saw Use 88135.02 Miscellaneous Correspondence R. Freudenberger, BWXT NOG-L ESH&S Manager letter to 01/27/2022 Director, Office of NMSS, "Annual Summary of Changes and Revised Integrated Safety Analysis" 88135.02 Miscellaneous E4-683 Instructions for Exclusive Use Vehicle Rev. 6 88135.02 Miscellaneous Job Order Title CLASSIFIED 1251506 88135.02 Miscellaneous N-50 Employee Review of Area Documents (Ref. CA 2022-0534) 05/18/2022 88135.02 Miscellaneous N-554 Critique Meeting Minutes (CA 2022-0534) 05/03/2022 88135.02 Miscellaneous N/A Uranium Recovery Blend Box - Mass/Moderating Materials 01/19/2022 Control Log (time stamps from 0101 thru 0454) 88135.02 Miscellaneous N/A N-554 Critique Meeting Minutes (CA 2022-0586) 05/05/2022 22

Inspection Type Designation Description or Title Revision or Procedure Date 88135.02 Miscellaneous N/A 2022 biennial drill packet including documentation of 04/18/2022 corrective actions and critiques 88135.02 Miscellaneous N/A BWXT NOG-L Physical Inventory Summary Report October 05/12/2022 2021/March 2022 88135.02 Miscellaneous N/A Preliminary NOG-L and LTC Dose Summary 2021 88135.02 Miscellaneous NFPA 484 Standard for Combustible Metals 2019 Edition 88135.02 Miscellaneous SAR 15.09 Main Extraction and Drum Dryer Processes in Uranium Rev. 106 Recovery 88135.02 Miscellaneous SAR 15.14 Scrubber Ventilation and Vacuum System in Uranium Rev. 76 Recovery 88135.02 Miscellaneous SAR 15.18 SFF Dry-End Processing SFF Operation Rev. 139 88135.02 Miscellaneous SAR 15.22 RTRT (Research Test Reactor and Targets) Fuel Powder Rev. 103 and Compact Processes 88135.02 Miscellaneous SAR Appendix Main Extraction and Drum Dryer Processes in Uranium Rev. 36 15.09 Recovery 88135.02 Miscellaneous TWR-HS-2009- RTRT Aluminum Powder Storage Room Rev. 0 157 88135.02 Procedures RP-06 Radiation Protection Manual - Radiation Work Permit Rev. 14 88135.02 Procedures RP-06-001 Radiation Protection Responsibilities of a Radiation Work Rev. 14 Permit 88135.02 Work Orders 20300352 Safety WO for Purging, Replacing, and Testing New SFF 04/25/2022 Process Gas Lines 88135.04 Corrective Action 2022-0361 UR inline monitor inconsistencies during daily/shift operability 05/17/2022 Documents checks Resulting from Inspection 88135.04 Drawings EBP-50004D Raffinate Tank Circular Design Rev. 1 88135.04 Drawings LT-3703-E 2 1/2-Liter Container Rack Rev. 3 88135.04 Drawings REC-2006-001 Mass/Moderator Rack Rev. 0 88135.04 Drawings UPRR-30073 Annular Organic Tank P&ID Rev. 1 88135.04 Drawings UPRR-30116 Annular Waste Tank P&ID Rev. 4 88135.04 Miscellaneous ISAP 96-00210 Fire Safety Historical Data Review of PHA-4 Processes Rev. 0 (Liquid and Solid Waste Handling in Scrap Recovery) 88135.04 Miscellaneous ISAP 96-00218 Fire Loading Calculation for Fire Area 14A-2 Rev. 0 23

Inspection Type Designation Description or Title Revision or Procedure Date 88135.04 Miscellaneous ISAP 99-00101 Fire Loading Calculation for Fire Area 15A-1 Rev. 2 88135.04 Miscellaneous N/A BWXT Demo Work Permit for WO 20300352 88135.04 Miscellaneous N/A RP-13-003-Form 1/2, Health Physics Audit Checklist - 3rd 09/22/2021 QTR 2021 88135.04 Miscellaneous N/A RP-13-003-Form 1/2, Health Physics Audit Checklist - 4th 12/15/2021 QTR 2021 88135.04 Miscellaneous N/A RP-13-003-Form 1/2, Health Physics Audit Checklist -1st 03/31/2022 QTR 2022 88135.04 Miscellaneous N/A Photomultiplier Tube Base/Preamplifier Model 2007P Revised Operator's Manual, Canberra Industries, Inc. 01/1991 88135.04 Miscellaneous N/A Model 802 Scintillation Detectors User's Manual, Canberra Revised Industries, Inc. 01/1991 88135.04 Miscellaneous N/A Test Plan for Addition of CIDAS Detectors 17, 28, and 39 88135.04 Miscellaneous SAR 15.12 Liquid and Solid Waste Handling Processes in Uranium Rev. 85 Recovery 88135.04 Miscellaneous SAR 15.12 Liquid and Solid Waste Handling Processes in Uranium Rev. 30 Appendix Recovery 88135.04 Procedures E61-023 Daily Inline Monitor Operation Check Rev. 15 88135.04 Procedures E61-644 Shift Inline Monitor Operation Check Rev. 4 88135.04 Procedures MP 3404 UR Annular Organic Tank Drain and Flush Preventive Maintenance (6-month) 88135.04 Procedures MP 579 UR Contactor Raffinate Column Vertical Low-Level Probe Check (6-month) 88135.04 Procedures OP-0061135 Operating Procedure for Waste Handling and Disposal Rev. 45 Enrichment and Uranium Recovery Facility 88135.04 Procedures OP-0061242 Operating Procedure for Inline Monitor System Rev. 37 88135.04 Work Orders 20232701 Clean Probe on Contactor Waste Column #2 11/16/2017 88135.04 Work Orders 20256549 Repair End Wire on Inline #1 01/26/2019 88135.04 Work Orders 20258591 SC SFF Calibrate Waste Inline Monitor (1 year) 04/29/2019 88135.04 Work Orders 20258909 Check Lights on UR Inline #4 02/23/2019 88135.04 Work Orders 20259228 SC UR Calibration Inline #1 (1 year) 03/26/2019 88135.04 Work Orders 20259801 Check Wires on Inline #2 03/18/2019 88135.04 Work Orders 20260510 Inline #1 Rustrack Not Reading 03/20/2019 24

Inspection Type Designation Description or Title Revision or Procedure Date 88135.04 Work Orders 20265906 SC UR Calibration Inline #2 (1 year) 07/29/2019 88135.04 Work Orders 20265907 SC UR Calibration Inline #3 (1 year) 08/12/2019 88135.04 Work Orders 20269009 SC UR Calibration Inline #4 (1 year) 12/09/2019 88135.04 Work Orders 20269944 Clean Low-Level Probe on Contactor Waste Column #2, 09/02/2019 88135.04 Work Orders 20275865 SC UR Calibration Inline #1 (1 year) 03/27/2020 88135.04 Work Orders 20277002 TRISO-Modify SFF Waste Inline Monitor Electrical Panel per CHG-7556 88135.04 Work Orders 20278963 SC SFF Calibrate Waste Inline Monitor (1 year) 04/29/2020 88135.04 Work Orders 20281270 SC UR Calibration Inline #1 (1 year) 04/01/2020 88135.04 Work Orders 20283295 SC UR Calibration Inline #2 (1 year) 08/20/2020 88135.04 Work Orders 20283296 SC UR Calibration Inline #3 (1 year) 07/13/2020 88135.04 Work Orders 20284390 Change Ends on Inline #2 and #3 06/09/2020 88135.04 Work Orders 20286448 SC UR Drain/Flush Annular Organic Tank (6 month) 09/30/2022 88135.04 Work Orders 20287152 Put Ends on Inline #2 07/17/2020 88135.04 Work Orders 20287618 Put New Ends on Inline #2 08/04/2020 88135.04 Work Orders 20289136 SC UR Calibration Inline #4 (1 year) 12/09/2020 88135.04 Work Orders 20296157 SC UR Drain/Flush Annular Organic Tank (6 month) 04/01/2021 88135.04 Work Orders 20296270 SC UR Calibration Inline #1 (1 year) 04/19/2021 88135.04 Work Orders 20296787 Check Bulbs on UR Inline #4 Light Tree 01/14/2021 88135.04 Work Orders 20297304 Red Light Malfunction on Inline Tower (UR Inline Monitor #4) 01/21/2021 88135.04 Work Orders 20299491 SC SFF Calibrate Waste Inline Monitor (1 year) 07/27/2021 88135.04 Work Orders 20304098 SC UR Calibration Inline #2 (1 year) 07/27/2021 88135.04 Work Orders 20304099 SC UR Calibration Inline #3 (1 year) 07/22/2021 88135.04 Work Orders 20304986 Pre-Fab and Install New Kynar for UR Inline Monitors 1-3 08/26/2021 88135.04 Work Orders 20306967 SC UR Drain/Flush Annular Organic Tank (6 month) 02/11/2022 88135.04 Work Orders 20307596 SC UR Calibration Inline #1 (1 year) 07/22/2021 88135.04 Work Orders 20309538 SC UR Contactor Raffinate Column Low-Level Probe (6 09/01/2021 month) 88135.04 Work Orders 20309885 SC UR Calibration Inline #4 (1 year) 11/16/2021 88135.04 Work Orders 20311694 Replace UR Inline Monitor #4 Power Supply 11/22/2021 88135.04 Work Orders 20311797 Inline #3 Wire Came Out 09/24/2021 88135.04 Work Orders 20315500 Repair Short on Inline #3 12/06/2021 88135.04 Work Orders 20318983 SC UR Contactor Raffinate Column Low-Level Probe (6 03/01/2021 25

Inspection Type Designation Description or Title Revision or Procedure Date month) 88135.04 Work Orders 20318983 SC UR Contactor Raffinate Column Low-Level Probe (6 03/17/2022 month) 88135.04 Work Orders 20320306 SC UR Inline Monitor #4 Alarm Test (1 month) 03/08/2022 88135.04 Work Orders 20321051 SC UR Inline Monitor #4 Alarm Test (1 month) 04/11/2022 88135.04 Work Orders 20321110 Replace Connector on Inline #3 03/12/2020 88135.04 Work Orders UPRR-30147 Inline Monitors 1, 2, and 3 Rev. 3 88135.05 Fire Plans Pre-Fire Plan - Information Sheet Section #15 12/29/2001 88135.05 Fire Plans Pre-Fire Plan - Information Sheet Section #16 03/28/2005 88135.05 Fire Plans Pre-Fire Plan - Information Sheet Section #16M 07/17/2014 88135.05 Fire Plans Pre-Fire Plan - Information Sheet Section #18 06/17/2019 88135.05 Fire Plans Pre-Fire Plan - Information Sheet Section #19 12/10/2016 88135.05 Fire Plans Pre-Fire Plan - Information Sheet Section #20 02/17/2010 88135.05 Fire Plans Pre-Fire Plan - Information Sheet Section #33 07/26/2011 88135.05 Fire Plans Pre-Fire Plan - Information Sheet Section #34 02/17/2010 88135.19 Engineering CHG-12069 CIDAS Addition of 3 Criticality Detectors to Bay 12A 05/05/2022 Changes 88135.19 Miscellaneous N/A Test Plan for Addition of CIDAS Detectors 17, 28, and 39 88135.19 Miscellaneous RP-07-103, Form CIDAS CAAS Failure and Non-Routine Maintenance Log completed 2 05/22/2022 88135.19 Miscellaneous RP-07-104, Form NOG-L CIDAS MkXI Criticality System Calibration (pages 2 completed 1 and 3) 05/22/2022 88135.19 Miscellaneous RP-07-104, Form Security Notification of CIDAS Annual Criticality Monitoring completed 2 System Logic Check 05/22/2022 88135.22 Drawings UPRR-30147 Inline Monitors 1, 2, and 3 P&ID Rev. 3 88135.22 Miscellaneous SAR 15.12 Liquid and Solid Waste Handling Processes in Uranium Rev. 84 Recovery 88135.22 Procedures E61-023 Daily Inline Monitor Operation Check Rev. 15 88135.22 Procedures E61-644 Shift Inline Monitor Operation Check Rev. 4 88135.22 Procedures OP-0061242 Operating Procedure for Inline Monitor System Rev. 37 26