ML21118B020

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Nuclear Fuel Services, Inc Integrated Inspection Report 07000143 2021001
ML21118B020
Person / Time
Site: Erwin
Issue date: 04/28/2021
From: Robert Williams
NRC/RGN-II
To: Stewart J
Nuclear Fuel Services
References
IR 2021001
Download: ML21118B020 (16)
v • d • e


Text

April 28, 2021 Mr. John A. Stewart President Nuclear Fuel Services, Inc.

P.O. Box 337, MS 123 Erwin, TN 37650-0337

SUBJECT:

NUCLEAR FUEL SERVICES, INC - INTEGRATED INSPECTION REPORT 07000143/2021001

Dear Mr. Stewart:

On March 31, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Nuclear Fuel Services, Inc. On April 19, 2021, the NRC inspectors discussed the results of this inspection with you 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.

During the inspection period, the U.S. NRC implemented alternative ways to complete the core inspection program for your facility when routine onsite inspections could not be performed due to the public health emergency declared by the Secretary of Health and Human Services on January 31, 2020 (as renewed on April 21, 2020, July 23, 2020, October 2, 2020, January 7, 2021, and April 21, 2021), and the National Emergency declared by the President of the United States on March 13, 2020 (and continued on February 24, 2021), concerning the novel coronavirus disease (COVID-19).

Additionally, the inspectors implemented measures during the inspection period to support the determination of reasonable assurance that the public and the environment will be adequately protected from the hazards related to the operation of your facility. These compensatory measures included activities such as supplemental reviews of licensee-submitted reports (e.g.

effluent reports, plant modification reports, and changes to the Integrated Safety Analysis Summary) and increased communications with your staff to discuss the status of plant operations.

The compensatory measures did not constitute direct inspection and were intended to address the impact of the COVID-19 public health emergency on the agencys routine oversight program, particularly on the continuous engagement with your facility via periodic site visits and in-person interactions. These proactive actions were taken to obtain additional insights into the safe operation of the facility during the COVID-19 public health emergency.

J. Stewart 2 The NRC will continue evaluating the guidelines and recommendations from federal and state authorities, along with the conditions of your facility, to determine how to best conduct inspections until normality can be achieved. In the interim, the NRC plans to conduct periodic resident inspector visits to the site and gradually increase their presence, as appropriate.

The NRC will also maintain compensatory measures and frequent communications with your staff to discuss regulatory compliance matters and gather information to inform the decisions about future inspections.

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,

/RA/

Robert E. Williams, Jr., Chief Projects Branch 1 Division of Fuel Facility Inspection Docket No. 07000143 License No. SNM-142

Enclosure:

As stated cc w/ encl: Distribution via LISTSERV

ML21118B020 SUNSI Non-Sensitive Publicly Available Review Sensitive Non-Publicly Available OFFICE RII:DFFI/PB1 RII:DFFI/PB1 RII:DFFI/PB1 RII:DFFI/PB1 NAME Larry Harris Joel Rivera Lindsey Cooke R. Williams DATE 4/14/2021 4/14/2021 4/14/2021 4/28/2021 U.S. NUCLEAR REGULATORY COMMISSION INSPECTION REPORT REGION II Docket Number: 07000143 License Number: SNM-142 Report Number: 07000143/2021001 Enterprise Identifier: I-2021-001-0109 Licensee: Nuclear Fuel Services, Inc.

Facility: Nuclear Fuel Services, Inc.

Location: Erwin, TN Inspection Dates: January 01, 2021 to March 31, 2021 Inspectors: L. Cooke, Fuel Facility Inspector L. Harris, Senior Resident Inspector J. Rivera-Ortiz, Sr. Fuel Facility Project Inspector Approved By: Robert E. Williams, Jr., Chief Projects Branch 1 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 Nuclear Fuel Services, Inc, 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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REPORT DETAILS PLANT STATUS The following facility process areas were operating during the inspection period: Naval Fuel Manufacturing Facility (FMF) and the Blended Low Enriched Uranium (BLEU) Preparation Facility (BPF), which includes the Uranium (U)-Metal, U-Oxide, Solvent Extraction and the down-blending lines.

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

SAFETY OPERATIONS 88020 - Operational Safety The inspectors evaluated selected aspects of the licensees Operational Safety program to verify compliance with selected portions of 10 CFR 70, including 70.61 and 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, fire safety, and chemical safety based on the information provided in the integrated safety analysis (ISA) summary. The process areas and accident sequences selected for review are listed below:

  • Area 600 Accident Sequences: 4.1.1.1.b.1, 4.1.2.1.a, 4.1.7.b, 4.1.10.1.b, 4.1.16, 4.1.17.b, and 4.1.1.4(a)
  • Area 800 Accident Sequences: 4.1.1.4.1, 4.1.10.4.2, 4.1.13.4.3, and 4.1.15.4.4.a 2

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. The specific safety controls selected for review are listed below:

  • Area 600 IROFS: FA5-003, FA6-001, FA6-002, FA6-005, FA6-006, FA6-012, FA6-021, FA6C-13, FA6C-30, FA6C-35, FA6C-36, and FMF-002
  • Area 800 IROFS: FA8-37, FA8-40, FA8-41, FA8-1, FA8-2, FA8-3, FA8-9, FA8-16, and FA8-17 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 a sample of implementing procedures for IROFS FA5-003, IROFS FA6-006, IROFS FA6C-36, and IROFS FMF-002
  • reviewed operating procedure SOP 401-08 for Area 800 to verify that IROFS were implemented in the procedure
  • conducted walk-downs and observed operations in Areas 600, 600 PSL, and 800 and interviewed operators to verify that selected IROFS were present and performed as intended
  • reviewed a sample of implementation data sheets (runsheets) for IROFS FA5-003
  • reviewed a sample of Area 800 runsheets to verify IROFS implementation
  • reviewed a Nuclear Criticality Safety Evaluation for Area 600 PSL to identify assumptions and boundary conditions and verify consistency with operating conditions
  • reviewed ISA Risk Assessment for Area 800 and Fire and Radiological Accident Consequence Evaluation to identify assumptions and boundary conditions and verify consistency with operating conditions 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:

  • reviewed a sample of surveillance test records for IROFS FA6-005 and FA6-006 in Area 600
  • reviewed a sample of surveillance test records for IROFS FA8-16, FA-87, FA8-40, and FA8-41 in Area 800 4
  • reviewed education and experience information for five recent management changes to verify compliance with the minimum qualification requirements in the license
  • interviewed licensee staff in charge of training and reviewed operator training material for Area PSL 600 and Area 800
  • reviewed training records for four operators assigned to Areas 600 and 600 PSL, and three operators assigned to Area 800
  • reviewed a sample of plant modifications associated with Areas 600 and 800 to verify that configuration management measures were consistent with the license requirements
  • reviewed a sample of problems entered in the Corrective Action Program related to IROFS issues in Areas 600 and 800 to verify that corrective action management measures were consistent with the license requirements
  • reviewed a sample of audits and self-assessments in the Operations Area
  • conducted walk-downs of Areas 600, 600 PSL, and 800 to determine whether housekeeping conditions had adverse effects on process safety or IROFS safety functions.

88135.02 - Plant Status The inspectors routinely conducted walk-downs 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 Title 10 of the Code of Federal Regulations (10 CFR) 70, Domestic Licensing of Special Nuclear Material.

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.

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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.

  • The following program entry numbers were reviewed: 81506, 81507, 81559, 81560, 81570, 81574, 81599, 81606, 81691, 81694, and 83079.

Event Review (IP Section 03.06)

The inspectors reviewed the plant event listed below to determine if the event warranted the use of formal event review criteria and to evaluate whether 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) and 20.2201, 20.2202, and 20.2203 (radiological and environmental events).

  • 21G-20-0151, "60-Day Written Notification of Event," dated December 16, 2020 (ADAMS ML21029A067). On September 15, 2020, the licensee shipped 40 empty ES-3100 shipping drums to the Y-12 National Security Complex. On November 4, 2020, Y-12 personnel identified that on one of the empty ES-3100 drums seven of the eight outer lid bolts were not tightened to the applicable specifications.

Audits (IP Section 03.07)

The inspectors reviewed the internal and/or external audits listed below to determine whether they were performed in accordance with 10 CFR 70.22(h)(1) and the license application.

  • Internal Audit: Health Physics 2020 Q4
  • Internal Audit: NCS and Inspections 2020 Q4
  • Internal Audit: Industrial Safety 2020 Q4
  • Internal Audit: ISA and Fire Protection 2020 Q4 Radiation Work Permit (RWP) (IP Section 03.09)

The inspectors reviewed and observed the safety work permits (SWPs) listed below to determine whether the SWPs contained the information required by Chapter 4, "Radiation Safety," of the license application; the Radiation Protection Manual; and implementing procedures:

  • SWP-21-14-006 302 Area 800, February 2021
  • SWP-21-002-009 302 - Area ABC, February 2021 6

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 Part 70, the license, 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 conducted walk-downs of the processes and systems listed below to evaluate their operational safety.

  • Waste Handling and Packaging IROFS: WSAT-1, WST-2, WST-3, and WST-4
  • 105 Laboratory IROFS: 6IR-2, LAB-7, LAB-8, LAB-9, LAB-13, LAB-15, LAB-21, LAB-27, LAB-37, LAR-1, and WWT-31 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 (SSCs) to verify compliance with the fire protection program as described in Chapter 7, Fire Safety of the license application, and the National Fire Protection Association (NFPA) 801, Standard for Fire Protection for Facilities Handling Radioactive Materials, as required. Also, the inspectors evaluated offsite fire brigade training and drill performance to verify compliance with Section 7.6.8 of Chapter 7, "Fire Safety" of the license application and NFPA 600 "Standard on Facility Fire Brigades."

Fire Area Walkdown (IP Section 03.01)

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

  • 234 Tent
  • Building 301 IROFS: Fire 28, 29, and 30 Fire Brigade Drill Performance Sample (IP Section 03.02)

The inspectors evaluated the annual fire brigade training and drill performance described below:

  • On March 3, 2021, the inspectors observed classroom and practical training sessions at an offsite location. On March 4 and 5, 2021, the inspectors observed live fire training conducted in a structure at an offsite facility that involved different scenarios used to show communication, entry techniques, the donning of protective gear and self-contained breathing apparatus, command and control, communications, and firefighting capability based on the state of Tennessee Commission Firefighter 1 Competency Evolution.

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88135.17 - Permanent Plant Modifications The inspectors evaluated implementation of the configuration management system (CMS) for facility changes or modifications to ensure that safety-related systems, structures, and components (i.e., IROFS or other credited safety controls) could adequately perform their intended safety function and that changes did not adversely impact the operability and safety of the facility.

Facility Change/Modifications (IP Section 03.01)

The inspectors reviewed replacement activities for the 304 vacuum pump to determine whether it was implemented in accordance with 10 CFR 70.72, Facility changes and change process. Specifically, the inspectors reviewed the following:

  • Engineering Change Request (ECR) 20150941, Vacuum Pump Replacement
  • Change Authorization for approved ECR 20150941
  • Technical Basis for ECR 20150941 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(s) following maintenance.

Post-Maintenance Testing (IP Section 03.01)

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

  • N333XXXXTE2P18A-333
  • N333XXXXTE2018A-333
  • N303XIGNTBSS672-303
  • N303VALVEBAA601-303 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 Integrated Safety Analysis.

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Surveillance and Calibration Testing (IP Section 03.01)

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

  • N333VALVH5AO1A-333
  • N333VALVH5AO1B-333
  • N333 PRSLEEVE002-333 INSPECTION RESULTS Minor Violation 88135.02 Minor Violation: 10 CFR 71.17(c)(2) states, in part, that each licensee shall comply with the terms and conditions of the license application, certificate, or other approval, as applicable. Certificate of Compliance Number 9315, Revision 15, which is applicable to ES-3100 Shipping Package, Safety Analysis Report Section 7.1.2.2, requires the outer lid bolts to be torqued to 30 ft-lb. Contrary to the above, on September 15, 2020, NFS shipped 40 empty ES-3100 shipping packages to the Y-12 National Security Complex and one of the ES-3100 packages (identification number USA/9315/B(U)F-96) was found to have seven of the eight outer lid bolts not tightened to the required torque specifications. No issues were found with the torque of the other 39 ES-3100 packages on the shipment. Additionally, no issues were found with the torque of the inner containment vessel closure nuts on any of the 40 ES-3100 packages on this shipment.

Screening: The inspectors determined the violation was minor. The inspectors' determination was based on the guidance in IMC-0616, Appendix B, for transportation issues because the affected package was empty and did not result in any release of licensed material or safety consequences.

Enforcement: The licensee entered the issue in the corrective action program as Problem Identification, Resolution, and Corrective System (PIRCS) item 81073 and determined that human failure was the probable cause of the event. The licensee established additional administrative controls, including an independent torque verification, to ensure compliance with torque requirements for shipping packages. This failure to comply with Certificate of Compliance No. 9315, Revision 15, constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.

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

  • On April 19, 2021, the inspectors presented the integrated inspection results to John A.

Stewart and other members of the licensee staff.

  • On March 11, 2021, the inspectors presented the operational safety inspection results to John A. Stewart and other members of the licensee staff.

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DOCUMENTS REVIEWED Inspection Type Designation Description or Title Revision or Procedure Date 88020 Calculations ISA Risk Assessment for Area 800 Rev. 6 88020 Calculations Fire Radiological Accident Consequence Evaluation Rev. 3 88020 Calculations 21X-19-0016 ISA Safety Basis Risk Assessment Support and Rev. 1 Justification (Areas 600 and PSL 600) 88020 Calculations 54X-11-0003 Configuration Control Equipment - Area 600 88020 Calculations 54X-12-0019 PSL Area 600 and 700A Operations Rev. 0 88020 Corrective Action PIRCS 78572 Area 800 02/10/2020 Documents 88020 Corrective Action PIRCS 78832 Area 600 3/05/2020 Documents 88020 Corrective Action PIRCS 80216 Area 600 8/10/2020 Documents 88020 Corrective Action PIRCS 80604 Area 600 9/25/2020 Documents 88020 Corrective Action PIRCS 80649 Area 600 10/1/2020 Documents 88020 Corrective Action PIRCS 80711 Area 600 10/07/2020 Documents 88020 Corrective Action PIRCS 81694 Area 800 01/29/2021 Documents 88020 Corrective Action Work Request Area 800 02/10/2020 Documents 290676 88020 Corrective Action Work Request Area 800 03/11/2021 Documents 295942 Resulting from Inspection 88020 Corrective Action Work Request Area 800 03/11/2021 Documents 295943 Resulting from Inspection 88020 Drawings 306-F0013-D Area 800 88020 Engineering ECR-20181451 Engineering Change Request - Area 600 (IROFS FA6- 11/16/2018 Changes 005) 88020 Miscellaneous 21T-19-0949 SNM-124 License Flowdown Chapter 11E, Audits and Rev. 2 10

Inspection Type Designation Description or Title Revision or Procedure Date Assessments 88020 Miscellaneous 21T-20-0109 SNM-124 License Flowdown Chapter 11C, Training and Rev. 2 Qualification 88020 Miscellaneous 27T-20-0110 SNM-124 License Flowdown Chapter 11F, Corrective Rev. 4 Action Program 88020 Miscellaneous 27X-20-0011 NFS Training Department - Lesson Plan PSL 600/700A 04/24/2020 88020 Miscellaneous OT-302-800 Area 800 Operator Training 09/19/2018 88020 Procedures LOA-2340A-005 Area 600 05/06/2020 88020 Procedures LOA-2340A-079 Area 800 Letter of Authorization 02/03/2021 88020 Procedures MFS-WM-009 NFS Preventive Maintenance Program 1 88020 Procedures NFS-GH-43 Safety-Related Equipment Control Program Rev. 31 88020 Procedures NFS-HS-A-68 ISA Risk Assessment Procedure Rev. 9 88020 Procedures NFS-HS-CL-10 Nuclear Criticality Safety Fuel Manufacturing Facility (U) Rev. 31 88020 Procedures NFS-OPS-001 Conduct of Operations 12 88020 Procedures NFS-PD-001 Management of the On-Line Training and Qualification 7 (T&Q) System 88020 Procedures NFS-WM-001-2 Work Control Process 5 88020 Procedures NFS-WM-005 Conduct of Maintenance Operations 3 88020 Procedures SOP 358 General Maintenance 22 88020 Procedures SOP 401-04-302 Area 400 (U) Rev. 46 88020 Procedures SOP 401-06 Area 600(U) Rev. 1 88020 Procedures SOP 401-06A-303 Area 600 PSL (U) Rev. 4 88020 Procedures SOP 401-08 Area 800 Rev. 30 88020 Procedures SOP 401-14 300 Complex Rev. 30 88020 Procedures SOP 401-500-302 Area 500 Accountability and Storage Building 302 (U) Rev. 16 88020 Self- 56T-19-0151 Integrated Safety Analysis (ISA) Audit Report (QA-19-19) 09/26/2019 Assessments 88020 Self- 56T-20-0045 Monthly Walkdown of Configuration-Controlled Piping and 03/19/2020 Assessments Instrumentation Diagram 88020 Self- 56T-20-0089 Monthly Walkdown of Configuration-Controlled Piping and 07/20/2020 Assessments Instrumentation Diagram 88020 Work Orders Area 800 Runsheets 07/22/2019 88020 Work Orders N302VALVEBA0522 Safety-Related Equipment Test - IROFS FA6-006 07/15/2020 88020 Work Orders N302VALVEBAA525 Safety-Related Equipment Test - IROFS FA6-006 10/29/2020 11

Inspection Type Designation Description or Title Revision or Procedure Date 88020 Work Orders N302VALVEBAB525 Safety-Related Equipment Test - IROFS FA6-006 01/04/2021 88020 Work Orders N302VALVEFV0601 Safety-Related Equipment Test - IROFS FA6-005 07/09/2020 88020 Work Orders N302VALVEFVA601 Safety-Related Equipment Test - IROFS FA6-005 01/18/2021 88020 Work Orders N302VALVEFVB601 Safety-Related Equipment Test - IROFS FA6-005 01/19/2021 88020 Work Orders N303VALVEBAA525 Safety-Related Equipment Test - IROFS FA6-006 10/08/2020 88020 Work Orders N303VALVEBAA601 Safety-Related Equipment Test - IROFS FA6-005 10/08/2020 88020 Work Orders N303VALVEBAB525 Safety-Related Equipment Test - IROFS FA6-006 10/08/2020 88020 Work Orders N303VALVEBAB601 Safety-Related Equipment Test - IROFS FA6-005 10/08/2020 88020 Work Orders N306VALVEBAA858 Safety-Related Equipment Test - IROFS FA8-40 09/14/2020 88020 Work Orders N306VALVEBAA864 Safety-Related Equipment Test - IROFS FA8-40 09/13/2020 88020 Work Orders N306VALVEBAA870 Safety-Related Equipment Test - IROFS FA8-40 09/14/2020 88020 Work Orders N306VALVEBAA8A0 Safety-Related Equipment Test - IROFS FA8-41 09/14/2020 88020 Work Orders N306VENDRAIN004 Safety-Related Equipment Test - IROFS FA8-37 03/19/2020 88020 Work Orders N306VENDRAIN010 Safety-Related Equipment Test - IROFS FA8-37 11/14/2020 88020 Work Orders N306XFILTERA807 Safety-Related Equipment Test - IROFS FA8-16 01/31/2021 88020 Work Orders N306XFILTERB87 Safety-Related Equipment Test - IROFS FA8-16 01/31/2021 88020 Work Orders N306XOVRFLOA802 Safety-Related Equipment Test 01/31/2020 88020 Work Orders N306XOVRFLOA802 Safety-Related Equipment Test 01/29/2021 88020 Work Orders N306XOVRFLOA802 Safety-Related Equipment Test 02/03/2021 88020 Work Orders N307VALVEBAB858 Safety-Related Equipment Test - IROFS FA8-40 09/13/2020 88020 Work Orders N307VALVEBAB864 Safety-Related Equipment Test - IROFS FA8-40 09/13/2020 88020 Work Orders N307VALVEBAB870 Safety-Related Equipment Test - IROFS FA8-40 09/13/2020 88020 Work Orders N307VALVEBAB8A0 Safety-Related Equipment Test - IROFS FA8-41 09/13/2020 88020 Work Orders N307VALVEBAB8D4 Safety-Related Equipment Test - IROFS FA8-40 09/13/2020 88020 Work Orders N307VENDRAIN029 Safety-Related Equipment Test - IROFS FA8-37 03/19/2020 88020 Work Orders N307VENDRAIN031 Safety-Related Equipment Test - IROFS FA8-37 06/14/2020 88020 Work Orders N307XFILTERC807 Safety-Related Equipment Test - IROFS FA8-16 01/31/2021 88020 Work Orders SOP 401-04-302 Attachment C, Runsheet 4C, Collection Column Data (U) 01/07-12/2021 88020 Work Orders SOP 401-04-302 Attachment C, Runsheet 4C, Collection Column Data (U) 1/14-19/2021 88135.02 Corrective Action 81506, 81507, Documents 81559, 81560, 81570, 81574, 81599, 81606, 81691, 81694, 83079 12

Inspection Type Designation Description or Title Revision or Procedure Date 88135.02 Corrective Action 82700, 82752, 82863 Documents Resulting from Inspection 88135.02 Procedures NFS-WM-001-02 Work Control Process Rev. 5 88135.17 Procedures NFS-TS-009 Configuration Management of Process Change Rev. 9 13

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