ML22024A269

BWXT Nuclear Operations Group, Inc. - Lynchburg - Integrated Inspection Report 07000027/2021004

ML22024A269
Person / Time
Site:	BWX Technologies
Issue date:	01/25/2022
From:	Eric Michel BWXT
To:	Bittner J BWXT
References
IR 2021004
Download: ML22024A269 (34)

Text

January 25, 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 07000027/2021004

Dear Mr. Bittner:

On December 31, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at BWXT Nuclear Operations Group, Inc. - Lynchburg. On January 25, 2022, 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.

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/

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

ML22024A269 X Non-Sensitive X Publicly Available X SUNSI Review Sensitive Non-Publicly Available OFFICE RII/DFFI RII/DFFI RII/DFFI RII/DFFI RII/DFFI RII/DFFI NAME A. Alen T. Sippel P. Startz G. Goff M. Ruffin E. Michel DATE 1/19/22 1/19/22 1/19/22 1/19/22 1/19/22 1/25/22 U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number: 07000027 License Number: SNM-42 Report Number: 07000027/2021004 Enterprise Identifier: I-2021-004-0035 Licensee: BWXT Nuclear Operations Group, Inc.

Facility: BWXT Nuclear Operations Group, Inc. - Lynchburg Location: Lynchburg, VA Inspection Dates: October 1, 2021 to December 31, 2021 Inspectors: A. Alen, Senior Resident Inspector G. Goff, Fuel Facility Inspector M. Ruffin, Fuel Facility Inspector T. Sippel, Fuel Facility Inspector P. Startz, 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 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 (10 CFR) 70, "Domestic Licensing of Special Nuclear Material," including 70.61, 70.62; 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/or 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 selected for review are listed below:

low-level dissolution (LLD) process recovery furnace system the inspectors also observed other ongoing processing and maintenance activities in UR Review of Safety Controls and Related Programs (IP Section 02.02)

The inspectors reviewed information related to administrative, active engineered, and passive safety controls or items relied on for safety (IROFS) for the areas 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 3

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

liquid detectors on double walled pipes, an active engineered control for chemical safety in UR drip shields above gloveboxes, a passive control to prevent the introduction of moderator into glovebox for criticality safety mass/moderator tracking and logs, an administrative control for criticality safety in the recovery furnace system geometry controls on the recovery furnace system, passive controls for criticality safety drains on recovery furnace system gloveboxes, a passive control for criticality safety mass tracking logs, an administrative control for criticality safety in the LLD system geometry controls of equipment used in the LLD system, passive controls for criticality safety limited use of moderating materials around the LLD hood, an administrative control for criticality safety 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:

walked down various passive engineered IROFS features identified in drawing UPRR 30129 to verify implementation of IROFS for the UR furnace system reviewed operating procedures (e.g., OP-0061450, OP-0061556) and interviewed operators for IROFS applied to the recovery furnace system reviewed NCS postings 15-25-002 and 15-25-003 for administrative IROFS applied to the recovery furnace system observed operators performing the mass/moderator measurements, calculations and logs when adding or removing material from gloveboxes walked down the LLD system to verify the as-built state of the IROFS matched system drawing UPRR 30060 reviewed LLD system operating procedures and interviewed and observed system operator's implementation of administrative IROFS observed operators perform mass calculations for each batch of material being processed in the LLD system 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 4

10 CFR 70 and applicable sections of the license application. Specifically, the inspectors conducted the following:

reviewed maintenance plans (MPs) and work orders (WOs) for IROFS in the areas above reviewed corrective action program (CAP) entries and documents related to operational issues and IROFS performance reviewed IA-SAR-2021-02-01, "Internal Audit Summary Report," which summarized licensee audit activities required by license application Section 11.5.1.5, "Quality Assurance Audits" reviewed training documents (e.g., TP-REC-0011 and Container Control/FAS Training Script - 2021) and interviewed operators assigned to the recovery furnace system observed activities related to operations in the recovery furnace system and LLD reviewed training records of the operators of the LLD system reviewed recent modification packages of changes made to the LLD system 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, 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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Posting of Notices (IP Section 03.04)

The inspectors reviewed the following notices to determine if they were posted in accordance with 10 CFR 19.11:

postings relevant to 19.11(a)(1) - (3) and 19.11(e) (i.e., NRC Form 3) located in the protected area and waste treatment facility Identification and Resolution of Problems (IP Section 03.05)

The inspectors reviewed the selected issues below 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:

corrective action (CA) 2021-1266, UR furnace (WS-401) operations blender unexpectedly started while being loaded with SNM on August 27, 2021, report date November 16, 2021 CA 2021-1440, RTR compact SNM content out of specification on October 1, 2021, report date October 21, 2021 CA 2021-1643, elevated U-235 concentration in UR raffinate waste tanks due to uranyl nitrate solution overflow from evaporator no. 1 on November 22, 2021, report date December 29, 2021 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)) and 20.2201, 20.2202, and 20.2203 (radiological and environmental events):

loose hardware identified on shipping container on October 11, 2021 (CA 2021-1490) specialty fuel facility (SFF) TRISO furnace (WS-300) did not initiate systematic shutdown during interlock test of facility alarm system (FAS) detector A3-LEL-T-01 (IROFS) on November 2, 2021 (CA 2021-1555) encapsulated fuel components cut in non-fuel workstation on November 4, 2021 (CA 2021-1568) elevated U-235 concentration in UR raffinate waste tanks on November 22, 2021 (CA 2021-1643)

Audits (IP Section 03.07)

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

External Audit: Nuclear Criticality Safety Program - Triennial Independent Assessment dated October 2020 6

External Audit: Nuclear Safety Culture Assessment of BWX Technologies Nuclear Operations Group dated June 27, 2021 Semi-Annual Effluent Monitoring Report dated August 24, 2021 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 21-0055, "Clean Bay 12A 'Do All' Saw," Rev. 0, conducted November 16, 2021 RWP 21-0013, "Loading and Transporting Down-Blend Decontamination and Decommissioning Waste Drums in Bays 14A and 15A (Task 3)," Rev. 0, conducted November 17, 2021 Annual Security and Emergency Preparedness Drills/Exercises (IP Section 03.10)

The inspectors observed the licensees performance during the actual emergency preparedness response and security force-on-force tactical response exercise listed below to determine they were being implemented in accordance with 10 CFR 70.22(I)(3) and/or 10 CFR 73.46(b)(9):

Force-on-force tactical response exercise conducted on October 20, 2021.

On November 4, 2021, BWXT activated their Emergency Operations Center after identifying an incident where encapsulated fuel components were inadvertently cut in a non-fuel cutting operation (CA 2021-1568). The inspectors evaluated the emergency management organization command and control, communications, accident assessment (i.e., radiological, criticality safety, and transportation), and event classification.

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 safety analysis report (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 and sub-systems of the listed processes associated with the following operation areas:

SAR 15.34, "Conventional Fuel Operations," Rev. 72.

automated storage unit (AFSU) chest carts storage chests conventional glovebox lines 7 and 8 7

evacuation system (PSES) residue glovebox SAR 15.42, "Container Storage Facility," Rev. 10.

container storage facility rack shipping containers 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) 80, "Standard for Fire Protection for Facilities Handling Radioactive Materials," as required.

Fire Area Walkdown (IP Section 03.01)

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

main bays 6, 7, 8, 9, and 10 Fire Brigade Drill Performance Sample (IP Section 03.02)

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

On October 9, 2021, the inspectors observed fire brigade training as part of the licensees annual emergency team training program to verify compliance with the license and NFPA 600, Standard on Industrial Fire Brigades. The inspectors observed both classroom and practical (i.e., hands-on) training sessions involving use of self-contained breathing apparatus (SCBA), forcible entry tools (e.g., halligan bar and flat-head axe), and search/rescue operations using a FAST (firefighter assistance search team) Board. The inspectors also observed a live-fire drill evolution in the 'burn' building. The drill evaluated fire brigade member application of the job performance requirements covered during the classroom/practical training sessions. The inspectors observed fire brigade leader command and control, proper donning and use of turnout gear and SCBA, availability of firefighting equipment, clear and effective radio communications, and implementation of pre-planned strategies.

88135.17 - Permanent Plant Modifications The inspectors evaluated implementation of the configuration management system 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.

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 WO instructions to confirm functional capability of the IROFS and/or safety controls following maintenance.

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Post-Maintenance Testing (IP Section 03.01)

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

WO 20313324, UPRR high-level dissolvers p-trap leak and obstruction inspection following p-trap piping changes per change evaluation CHG-8332; inspection conducted on November 13, 2021 OP-1001828, interlock test for FAS detector A6-ACPR-T-02 following troubleshooting maintenance (WO 20314587); test conducted on November 15, 2021 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.

Surveillance and Calibration Testing (IP Section 03.01)

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

OP-1001828, "FAS Interlocks and Furnace Testing in SFF - Finishing Furnace WS-300 (procedure Section H)," conducted October 20 and November 2, 2021 MP-4181 (WO 20313307), "Recovery Columns Process Water Valves Leak Test (Annual)," conducted November 29, 2021 RADIOLOGICAL CONTROLS 88030 - Radiation Protection The inspectors evaluated selected aspects of the licensees radiation protection program to verify compliance with selected portions of 10 CFR 20 and 61; Chapter 4, Radiation Safety, of the facilitys license application; and applicable licensee procedures.

Radiation Protection Program Implementation (IP Section 02.01)

The inspectors reviewed licensee procedures and other documentation related to the implementation of the radiation protection and radioactive waste programs to verify compliance with 10 CFR 20.1101(a). Specifically, the inspectors reviewed the following documents or observed the following:

RPTWR 2021-034, "iLink to Sentinel Interface Application, Area RP-07,"

August 24, 2021 (custom application created to connect seven iMatic counters to the Sentinel database) 9

Radiation Protection Manual the radiation protection department's independence from operations during walkdowns of UR, filler, SFF, down blend, waste treatment facility, Lynchburg Technology Center (LTC), and the radiological waste area Radiation Protection Program Review (IP Section 02.02)

The inspectors reviewed the licensees as low as reasonably achievable (ALARA) reports and audit/self-assessment records to verify compliance with 10 CFR 20.1101(c) and 20.2102. Specifically, the inspectors reviewed the following:

2020 ALARA Report, May 2021 December 2020 to October 2021 ALARA meeting minutes BWXT/NFS Waste Vendor Audit - Energy Solutions, Clive Site dated November 5, 2021 Section 4.1 of the license application radiation protection/health physics quarterly audits:

o 4th Quarter 2020 o 1st, 2nd, and 3rd Quarter 2021 corrective actions:

o 2019-0770 o 2020-0291 o 2020-0772 o 2021-0532 o 2021-1358 Radiation Protection and Radioactive Waste Procedures (IP Section 02.03)

The inspectors assessed the licensees procedure review requirements to verify compliance with Chapter 4.1, "Administrative Philosophy," of the license application. Specifically, the inspectors completed the following:

Reviewed the document review tracking system to verify the following procedures were reviewed at the required 5-year frequency:

o RP-03-010, "Plant Wide External Radiation Surveys," Rev. 9 o RP-05-011, "Respiratory Protection Selection & ALARA Evaluations,"

Rev. 6 o RP-07-004, "Calibration of Air Sampling Flow Meters," Rev. 10 o RP-08-022, "Environmental Air Sample Collection & Analysis," Rev. 14 o RP-15-003, "Handling Radioactive Sources," Rev. 4 Training (IP Section 02.04)

The inspectors interviewed licensee staff and reviewed radiation protection-related training records to verify compliance with 10 CFR 19.12, 19.13, and Section 4.2, "Training," of the license application. Specifically, the inspectors performed the following:

reviewed electronic training records for four new radiation protection employees (RP-10-001, Form 1, dated May 22, 23, and June 12, 13, 2021) interviewed the radiation technician supervisor 10

Radiation Work Permits (IP Section 02.06)

The inspectors interviewed licensee staff and reviewed RWPs to verify compliance with RP-06, "Radiation Work Permit," Rev. 14; Section 4.1 of the license application; and the corresponding section of the Radiation Protection Manual. Specifically, the inspectors reviewed and observed the following:

RWP 21-0006, "Equipment Removal in Down Blend" RWP 21-0007, "Equipment Removal in Zones 5 & 6 in 14A" RWP 21-0048, "Package Non-Fissile Excepted Bottles in 55-Gallon Drums for Future Disposition in TP Solids" RWP 21-0060, "WS-145 Temporary Operation" LTC-21-19, "Health Physics and Radiological Surveillance in High Radiation Areas" LTC-21-22, "Routine Entries into Building J and Building J Annex" RWPs were available at the location of the specialized work as per procedure Instrument Calibration (IP Section 02.07)

The inspectors interviewed licensee staff and reviewed radiation protection instrument calibration records to verify compliance with 10 CFR 20.1501(c), 10 CFR 70.24(a), and Section 4.3.2, "Instrumentation," of the license application. Specifically, the inspectors:

reviewed RP-07-057, "General Procedure for Calibration and Control of Radiation Protection Instrument," Rev. 24 reviewed numerous calibrations records: three each for alpha, beta, and gamma detection; one for neutron detection; hand and foot contamination monitors; personnel contamination monitors; air filter analyzers; lapel air samplers; fixed air flow meters; and the criticality accident alarm system reviewed the radiation control information system, the computerized system used for identifying instruments coming due for calibration observed calibration stickers on several contamination survey meters in intermediate control areas Instruments and Equipment (IP Section 02.08)

The inspectors observed the licensees use of radiation detecting instruments and equipment to verify compliance with 10 CFR 20.1501(a), 70.24(b), and Section 5.1.5, "Nuclear Criticality Monitoring System," of the license application. Specifically, the inspectors observed implementation of the following equipment/instruments:

criticality accident alarm system alpha, beta, and gamma survey meters Tennelec and iMatic alpha/beta proportional counters (used for air filters) personnel and hand & foot contamination monitors 11

Posting (IP Section 02.09)

The inspectors observed the posting of radiation areas and radioactive material storage areas to verify compliance with 10 CFR 20.1902(a)(b) & (d) and Section 4.3.6, "Caution Signs and Labels," of the license application. Specifically, the inspectors observed postings in the following areas:

radiation area postings in UR, filler, waste treatment facility, radiological waste storage, and along the fence line very high radiation area postings at LTC Container Labeling (IP Section 02.10)

The inspectors observed the labeling of packages and containers that contain radioactive material to verify compliance with 10 CFR 20.1902(e), 20.1904, 20.1905 and applicable sections of the license application, including Section 4.3.6. Specifically, the inspectors observed labeling in the following areas:

UR, filler, waste treatment facility, radiological waste storage, and other areas Posting of Notices (IP Section 02.11)

The inspectors observed the posting of notices to verify compliance with 10 CFR 19.11.

Specifically, the inspectors observed the following notice:

NRC Form 3, "Notice to Employees," located at the main security building and LTC entry Access Control (IP Section 02.12)

The inspectors observed the licensees access control measures to high radiation areas to verify compliance with 10 CFR 20.1601. Specifically, the inspectors observed:

high radiation area postings at the following two areas of the LTC:

o storage building behind a locked chain link fence and with locked doors o within the LTC basement; also, behind a locked interior chain link fence and locked door Radiation Surveys (IP Section 02.14)

The inspectors reviewed records of the licensees external radiation surveys to verify compliance with 10 CFR 20.1501(a), 20.2103, and Section 4.3.1.2.1, "Protection of Personnel from External Radiation," of the license application. Specifically, the inspectors reviewed:

records for RP-03-010 (Forms 1 and 2), Plantwide Gamma Surveys for 2020 12

Contamination Control (IP Section 02.15)

The inspectors observed a contamination survey and fixed air surveys and reviewed records of the licensees contamination control program to verify compliance with 10 CFR 20.1501(a), 20.2103, and Section 4.3.1.2.1 of the license application. Specifically, the inspectors:

observed a contamination survey within the filler area observed fixed air sampler filter change-outs in UR reviewed recent contamination records Sealed Sources (IP Section 02.16)

The inspectors observed the licensees storage and control of NRC licensed sealed sources and reviewed records of to verify compliance with Section 4.3.3.5, "Sealed Sources," of the license application. Specifically, the inspectors:

observed control and storage of sealed sources reviewed/verified records of sealed source locations and custody interviewed the licensee person in charge of the sealed source program Occupational Dose Results (IP Section 02.17)

The inspectors reviewed records of the occupational doses assigned to workers to verify compliance with 10 CFR 20.1201, 20.1207, and Section 4.3.1, "Protection of Personnel from Radiation Exposure," of the license application. Specifically, the inspectors:

reviewed the dose records for several licensee employees Exposure Controls (IP Section 02.18)

The inspectors observed engineering controls used to keep doses ALARA by monitoring the concentration of radioactive material in air, limiting intake, and establishing the ventilation such that air flows from areas of lower contamination potential into areas of higher contamination potential to verify compliance with 10 CFR 20.1701 and Sections 4.3.1.1.3, 4.3.5.1.6, and 4.3.5.2.5 of the license application. Specifically, the inspectors:

observed the air flow of gloveboxes and vapor hoods observed that ventilation inside SNM buildings was maintained such that air flows were from areas of lower contamination potential into areas of higher contamination potential observed the implementation of fixed air monitors and personnel lapel air samplers Bioassay Program (IP Section 02.19)

The inspectors interviewed licensee staff and reviewed the bioassay program to verify compliance with 10 CFR 20.2103(b)(3) and applicable sections of the license application.

Specifically, the inspectors:

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reviewed bioassay records for employees required to participate in the bioassay program interviewed the licensee about quality assurance of the vendor used for processing the licensee's bioassay samples; noted that the licensee audits the vendor Dosimetry (IP Section 02.21)

The inspectors interviewed licensee staff, observed dosimetry being worn, and reviewed dosimetry records to verify compliance with 10 CFR 20.1501(d), 20.1502(a), and Sections 4.3.1.2.1 and 4.3.2 of the license application. Specifically, the inspectors:

interviewed the senior health physicist responsible for administering the dosimetry program verified that the dosimeter processor is accredited by the National Voluntary Laboratory Accreditation Program reviewed dosimetry records for multiple licensee workers that handle SNM observed workers in UR, filler, waste treatment facility, and LTC wore dosimetry as required Dose Assessment Programmatic Review (IP Section 02.22)

The inspectors interviewed licensee staff and reviewed records and calculations related to the licensees assessment of the dose to workers to verify compliance with 10 CFR 20.1202, 20.1204, 20.1502(b), and 20.2106, and applicable sections of the license application (Section 4.3, "General Radiation Protection"). Specifically, the inspectors:

interviewed the licensee personnel responsible for dose assessment reviewed external dose, internal dose, and total dose records for several licensee workers with focus on the most at-risk employees As Low As Reasonably Achievable (ALARA) (IP Section 02.23)

The inspectors interviewed licensee staff and reviewed records related to the implementation of the ALARA program to verify compliance with 10 CFR 20.1101(b) and applicable sections of the license application (Section 4.1). Specifically, the inspectors:

reviewed the 2020 ALARA report reviewed the ALARA meeting minutes for the last 12 months interviewed the radiation protection unit manager 88045 - Effluent Control and Environmental Protection The inspectors evaluated selected aspects of the licensees environmental protection program to verify compliance with selected portions of 10 CFR 20, Part 40, and Part 70, and the facilitys license application.

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Program Implementation (IP Section 02.01)

The inspectors reviewed any significant changes to the effluent control and environmental protection program, discussed with the licensee any new unplanned releases or contamination identified, and screened the CAP to verify the environmental protection program was being implemented in compliance with license requirements. Specifically, the inspectors reviewed the following documents and/or discussed the following areas:

sample results at onsite environmental sample location #4, which included reviewing CA 2020-1221, licensee sample records, and the licensee's evaluation of whether or not this constituted new contamination walked down this and other locations where the licensee takes onsite environmental samples Audits and Quality Assurance (IP Section 02.03)

The inspectors reviewed procedures associated with the conduct of audits and assessments along with completed third-party and self-assessed audits and resulting corrective action entries assessed with the environmental protection program since the last inspection to verify compliance with license application requirements. Specifically, the inspectors completed the following activities:

reviewed licensee audits of vendors that analyze environmental samples for the licensee including EA-GEL-2021-06-07 and EA-NMIS-21-04-14 reviewed the 2020 ALARA report reviewed the last three semi-annual effluent reports Event Review (IP Section 02.04)

The inspectors reviewed the licensees evaluation of safety-significant events in the area of environmental protection to verify compliance with 10 CFR 20 and license application requirements. Specifically, the inspectors reviewed the following:

CA 2020-1221, including the licensee's follow-up surveys and evaluations Training (IP Section 02.05)

The inspectors reviewed the licensees training program in the area of environmental protection to verify compliance with license application requirements. Specifically, the inspectors reviewed the following:

RP-10-001, "Radiation Control Supervisor and Technician Training," Rev. 15 discussed training with technicians performing environmental duties Radioactive Liquid Effluents (IP Section 02.06)

The inspectors reviewed sample collection and analysis procedures, reviewed radiological effluent monitoring reports and monitoring records, and discussed the radioactive liquid effluent results with licensee staff to verify compliance with aspects of 10 CFR 20.2103 and the license application. Specifically, the inspectors completed the following activities:

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observed sample collection locations walked down the onsite environmental laboratory and discussed sample analysis with technicians reviewed sample collection records and results reviewed and discussed dose calculations and results Radioactive Airborne Effluents (IP Section 02.08)

The inspectors observed operations, reviewed sample collection and analysis procedures, reviewed radiological effluent monitoring reports and monitoring records, and discussed the radioactive airborne effluent results with licensee staff to verify compliance with aspects of 10 CFR 20.1101, 10 CFR 20.2103, and the license application. Specifically, the inspectors completed the following activities:

observed sample collection from multiple dry stacks and a wet scrubber walked down the onsite environmental laboratory and discussed sample analysis with technicians reviewed sample collection records and results reviewed and discussed dose calculations and results Effluent Monitoring (IP Section 02.09)

The inspectors observed operations, reviewed records, and discussed the results with the licensee to verify compliance with the license application. Specifically, the inspectors completed the following activities:

discussed potential paths of inadvertent discharge to waste tanks reviewed records of monitoring of non-contaminated effluents and systems that ensure such releases do not include radioactive material Semiannual Effluent Reports (IP Section 02.10)

The inspectors reviewed the licensees effluent monitoring report to verify compliance with the requirements of 10 CFR 70.59. Specifically, the inspectors completed the following activities:

reviewed inputs to the semi-annual effluent reports and compared results with the 2020 ALARA report Public Dose Analysis (IP Section 02.12)

The inspectors reviewed dose assessment records and associated reports to verify compliance with 10 CFR 20.1301, 10 CFR 20.1302, and the reporting requirements of 10 CFR 20.2107. Specifically, the inspectors completed the following activities:

reviewed public dose assessment records interviewed licensee staff concerning calculations of the public dose 16

Environmental Sampling (IP Section 02.13)

The inspectors reviewed environmental sampling records of surface water, sediment, soil, vegetation, ambient air, groundwater, and sewer sludge, to verify compliance with 10 CFR 20.1501 and the license application. Specifically, the inspectors completed the following activities:

observed and discussed adequacy of sampling points with the licensee reviewed records of specific environmental samples reviewed evaluations of exceeded action limits Minimizing Facility and Environmental Contamination and Facilitating Decommissioning (IP Section 02.14)

The inspectors reviewed decommissioning records to verify compliance with 10 CFR 70.25(g) and 10 CFR 20.1406. Specifically, the inspectors reviewed the following records:

STEC5_1013E, "BWXT NOG-L and LTC D and D Oversight Areas," Rev. 5 STEC9_1000E, "Contaminated Site Plan," Rev. 10 Radioactive Waste Classification, Characterization, and Storage (IP Section 02.15)

The inspectors reviewed and observed posting and labeling of storage areas and containers to verify compliance with the requirements of 10 CFR 61.55 and the license application. Specifically, the inspectors reviewed the following:

discussed the determination of any new waste streams or changes to existing ones with licensee staff observed radioactive waste storage areas and labeling or posting of exemption Waste Burial (IP Section 02.16)

The inspectors reviewed documentation and records of radioactive waste buried onsite prior to January 1981 to verify compliance with 10 CFR 20.2108, if applicable. Specifically, the inspectors reviewed the following records:

environmental sampling results (well water and surface samples) related to burial sites walked down onsite burial sites where radioactive waste was buried Effluent Treatment (IP Section 02.17)

The inspectors conducted walkdowns and observations of onsite waste treatment facilities and airborne effluent scrubbers and filters to verify compliance with the license application. Specifically, the inspectors completed the following activities:

walked down portions of the waste treatment facility and observed operations observed high-efficiency particulate air (HEPA) filters for selected systems interviewed licensee staff concerning waste treatment facility operations and 17

processes to remove radioactive material from wastewater and to monitor concentrations prior to releasing treated wastewater INSPECTION RESULTS No violations of more than minor significance were identified.

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

On January 25, 2022, the inspectors presented the integrated inspection results to James J. Bittner and other members of the licensee staff.

On November 10, 2021, the inspectors presented the Operational Safety inspection results to Rich Freudenberger and other members of the licensee staff.

On December 9, 2021, the inspectors presented the Radiation Protection and Effluent Control and Environmental Protection inspection results to Rich Freudenberger and other members of the licensee staff.

18

DOCUMENTS REVIEWED Inspection Type Designation Description or Title Revision or Procedure Date 88020 Corrective Action 2021-1358, 2021- Corrective action entries related to operational safety Documents 1266, 2021-1191, 2021-0975, 2021-0841, 2021-0648, 2021-0635, 2021-0605, 2021-1033, 2021-0626, 2021-0779 COM-91202 Corrective Action 2021-1565 Documents Resulting from Inspection Drawings 13AD2_1000 Low-Level Dissolvers Piping & Instrumentation Diagram (P&ID) Rev. 16 13AM1_1000 Bay 13A First Floor Exhaust Systems Rev. 22 UPRR 30009 13A Weigh Column Assembly 03/16/2010 UPRR 30060 Low-Level Dissolver Tray 03/09/2011 UPRR 30129 Recovery Conversion Furnace P&ID Rev. 1 UPRR 30160 Low-Level Dissolver System Rev. 00 UPRR 30162 13A Storage and Weigh Columns Rev. 00 Engineering CHG-10754 PVC Column Inspection MP Creation and MP 2192 Revision Rev. 0 Changes CHG-6843 Create Drawings for Ann Day Tank and Low-Level Dissolver 08/06/2019 System CHG-7012 Updating OP-0061137 After Removal of Filter Bowls and 09/05/2019 Piping CHG-9189 Change LLD Tray Design Material Thickness and Remove 09/14/2020 Thermowell Attachment CHG-9559 Replace Backup Argon Line in SFF Rev. 0 CHG-9784 Changes to SAR 15.06 Per Action Item 06211 01/13/2021 Miscellaneous Container Control/FAS Training Script - 2021 E61-001 Uranium Processing and Research Reactors OJT - Recovery Rev. 17 Operations 19

Inspection Type Designation Description or Title Revision or Procedure Date N/A Hydrofluoric Acid (HF) Safety Training 10/28/2021 N/A New Employee Safety Orientation 10/28/2021 NCS-2009-127 Nuclear Safety Release for SER 08-045, Phase 1 (Low-Level 09/11/2009 Dissolver Upgrades)

NCS-2010-079 Nuclear Safety Release for SER 08-045, Phase 1 (Low-Level 04/09/2010 Dissolver Upgrades)

QUAL-REC-0001 Recovery Qualification Card Rev. 1 SAR 15.25 Furnace Process Recovery Operation Rev. 38 SAR Appx. 15.06 Low-Level Dissolution Process in Uranium Recovery Rev. 29 SAR Appx. 15.25 Furnace Process Recovery Operation Rev. 14 TP-REC-0005 Training Plan for: Low-Level Dissolver (LLD) Area 02/25/2020 TP-REC-0011 Furnace Area 07/22/2020 Procedures E61-001 OJT - Recovery Operators Rev. 17 MP 3925 Annual Inspection of WS 401 Glovebox Integrity and to Ensure Glovebox Drains are Unobstructed MP 3926 Yearly Inspection to Confirm Dimensions MP 5147 PVC Column Inspection # 14A Weigh, Evap 6, and Contactor Extraction Area Columns MP 5148 PVC Column Inspection # Contactor Feed, Scrub Feed, Organic Phase Separator Columns NCS Posting 15- Recovery Furnace System Rev. 00 25-002 NCS Posting 15- Recovery Furnace System Cyclone Glovebox Rev. 2 25-003 OP-0061141 Low-Level Leach Hood Operation Rev. 66 OP-0061144 Low-Level Storage Column Operation Rev. 23 OP-0061169 Housekeeping and Decontamination in Uranium Recovery Rev. 14 Facility OP-0061214 LLD Accountability Weigh Column Operation Rev. 30 OP-0061234 Maintenance in UPRR Rev. 58 OP-0061450 General Safety and Safeguards Guidelines - UPRR Area Rev. 39 OP-0061556 Recovery Conversion Furnace Operation Rev. 22 Self-Assessments Audit Summary IH&S 3rd Quarter 2021 Audit 10/20/2021 20

Inspection Type Designation Description or Title Revision or Procedure Date Report IA-SAR-2021 Internal Audit Summary Report Rev. 0 01 Work Orders 20273976 Maintenance Plan (MP) 1185 SC HLD Weigh Gbox GP Hood 12/11/2019 Annual Inspection 20278998 SC WS 401 Fur Glbox/Drain Insp 1Y Reco 03/23/2021 20288738 Annual SC Inspection LLD Electrical Junction Boxes 09/03/2020 20294242 Annual SC HLD Weight GBox GP Hood Inspection 12/11/2020 20295744 MP 1807: Quarterly SC Nitric Acid Day Tank HL Alarm 01/21/2021 20295777 MP 2895: Quarterly SC Test Probe LLD HF 2" Column 01/29/2021 20298576 MP 636: 6-Month SC Inspection of Recovery Scrubber 04/23/2021 20299298 MP 3926: SC Insp WS 401 Tube Dimensions 1Y Reco 03/30/2021 20300401 MP 1479: Annual SC LLD Heat Tray System Shutdown 04/02/2021 20302872 MP 1718: Annual SC HL AL 5" COL LLD 05/31/2021 20305459 MP 2317: Annual SC Test of Recovery Scrubber Auxiliary Fan 07/12/2021 20305699 MP 1716: Monthly SC FLM HF SEC CONT LEAK DET 07/15/2021 20306325 MP 1453: 2-Month SC Inspection LLD for Buildup 07/13/2021 20306338 MP 1807: Quarterly SC Nitric Acid Day Tank HL Alarm 07/19/2021 20306358 MP 2895: Quarterly SC Test Probe LLD HF 2" Column 08/02/2021 20307709 MP 1840: Annual GP AL Nitrate 10/26/2021 20309423 Annual SC Inspection LLD Electrical Junction Boxes 09/01/2021 20309542 MP 636: 6-Month SC Inspection of Recovery Scrubber 09/29/2021 20309556 MP 1453: 2-Month SC Inspection LLD for Buildup 09/06/2021 20309900 MP 2411: Monthly SC HLTD and LLD Airflow Checks 09/08/2021 20311430 MP 1467: Quarterly SC HF Day Tank HL Probe 10/17/2021 20311439 MP 1716: Monthly SC FLM HF SEC CONT LEAK DET 10/14/2021 20311457 MP 2411: Monthly SC HLTD and LLD Airflow Checks 10/06/2021 20312553 MP 2192: GP Primary and Raff Preventative Mainten 11/01/2021 88030 ALARA Plans N/A BWXT NOG-L 2020 ALARA Report May 2021 Calibration N/A Neutron Detector Calibration by an Offsite Vendor 12/16/2020 Records and 06/29/2021 RP-07-010 Ludlum Model 2241 Digital Ratemeter with Alpha Scintillation Rev. 5 21

Inspection Type Designation Description or Title Revision or Procedure Date Form 1 Probe Calibration (for alpha instruments 2683 and 2732)

(06/24/2021, 06/25/2021, 12/02/2021, and 12/06/2021)

RP-07-017 Tennelec Series S5E Calibration (for instrument 2141) - Rev. 16 Form 1 12/17/2020 RP-07-017 Tennelec Series S5E Calibration (for instrument 1689) - Rev. 16 Form 1 08/17/2021 RP-07-017 Tennelec Series S5E Calibration (for instrument 1688) - Rev. 16 Form 1 07/27/2021 RP-07-017 Tennelec Series S5E Calibration (for instrument 2069) - Rev. 16 Form 1 08/16/2021 RP-07-017 Tennelec Series S5E Calibration (for instrument 2090) - Rev. 16 Form 1 05/26/2021 RP-07-017 Tennelec Series S5E Calibration (for instrument 2130) - Rev. 16 Form 1 09/29/2021 RP-07-017 Tennelec Series S5E Calibration (for instrument 2359) - Rev. 16 Form 1 11/10/2020 RP-07-022 Eberline RO-20 Calibration (for gamma instrument 1191) - Rev. 14 Form 1 (04/15/2021 and 10/28/2021)

RP-07-042 Ludlum Model 2241 Digital Ratemeter with G-M Detector Rev. 6 Form 1 Probe (for gamma instrument 3367) - Calibration (03/04/2021 and 09/08/2021 RP-07-043 Ludlum Model 2241 Digital Ratemeter with G-M Pancake Rev. 5 Form 1 Probe Calibration (for beta instruments 2715, 3175, and 3404)

(dates: 11/09/2020, 03/09/2021, 05/04/2021, 06/07/2021, 09/01/2021, 10/28/2021, 11/23/2021)

RP-07-044 Canberra Sirius-4AB Calibration (Personnel Contamination Rev. 6 Form 1 Monitor #2967) - (01/26/2021 and 07/21/2021)

RP-07-044 Canberra Sirius-4AB Calibration (Hand & Foot Contamination Rev. 6 Form 1 Monitor #2875) (12/08/2020 and 06/17/2021)

RP-07-044 Canberra Sirius-4AB Calibration (Hand & Foot Contamination Rev. 6 Form 1 Monitor #2680) - (12/10/2020 and 06/23/2021)

RP-07-044 Canberra Sirius-4AB Calibration (Hand & Foot Contamination Rev. 6 Form 1 Monitor #2800) - (01/26/2021 and 07/21/2021)

RP-07-044 Canberra Sirius-4AB Calibration (Hand & Foot Contamination Rev. 6 22

Inspection Type Designation Description or Title Revision or Procedure Date Form 1 Monitors #2726 and #2799) - (11/18/2020, 05/19/2021, and 11/16/2021)

RP-07-044 Canberra Sirius-4AB Calibration (Hand & Foot Contamination Rev. 6 Form 2 Monitor #3532) - (04/28/2021 and 10/27/2021)

RP-07-044 Canberra Sirius-5AB Calibration (Hand & Foot Contamination Rev. 6 Form 2 Monitor #3585) - (11/24/2020 and 11/16/2021)

RP-07-049 Out-of-Calibration Report - Canberra Argos-5AB Calibration Rev. 8 Form 1 (Personnel Contamination Monitor #3441) - (04/08/2021)

RP-07-049 Out-of-Calibration Report - Canberra Argos-5AB Calibration Rev. 8 Form 1 (Personnel Contamination Monitor #3440) - (04/12/2021)

RP-07-049 Out-of-Calibration Report - Canberra Argos-5AB Calibration Rev. 8 Form 1 (Hand & Foot Contamination Monitor # 3585) - (05/20/2021)

RP-07-057 MM1 Building - Criticality Accident Alarm System Annual Rev. 24 Form 1 Calibration - 2020 RP-07-057 MM1 Building - Criticality Accident Alarm System Annual Rev. 24 Form 1 Calibration - 2021 RP-07-057 RadCon - Criticality Accident Alarm System Annual Calibration Rev. 24 Form 1 - 2020 RP-07-057 RadCon - Criticality Accident Alarm System Annual Calibration Rev. 24 Form 1 - 2021 RP-07-058 Eberline HFM-7A Calibration (Hand & Foot Contamination Rev. 8 Form 1 Monitor #1984) - (01/26/2021 and 07/21/2021)

RP-07-069 Canberra Argos-4AB Calibration (Hand & Foot Contamination Rev. 4 Form 1 Monitor #2959) - (06/17/2021)

RP-07-069 Canberra Argos-5AB Calibration (Hand & Foot Contamination Rev. 4 Form 2 Monitor #3686) - (10/20/2021)

RP-07-072 Bicron Surveyor Model "MS" with Alpha Scintillation Probe Rev. 12 Form 2 Calibration (for alpha instrument 1795) - (03/04/2021 and 09/08/2021)

RP-07-100 Ludlum 9-4 Ion Chamber Calibration (for gamma instrument Rev. 4 Form 1 3100)

RP-07-105 Canberra LB4200 Calibration - Alpha/Beta Counter (for Rev. 6 Form 1 instrument 3362)

RP-07-105 Canberra LB4200 Calibration - Alpha-Beta Proportional Rev. 6 23

Inspection Type Designation Description or Title Revision or Procedure Date Form 1 Counter (for instrument 3363)

RP-07-105 Canberra LB4200 Calibration - Alpha-Beta Proportional Rev. 6 Form 1 Counter (for instrument 3364)

RP-07-105 Canberra LB4200 Calibration - Alpha-Beta Proportional Rev. 6 Form 1 Counter (for instrument 3365)

RP-07-105 Canberra LB4200 Calibration - Alpha-Beta Proportional Rev. 6 Form 1 Counter (for instrument 3368)

RP-07-105 Canberra LB4200 Calibration - Alpha-Beta Proportional Rev. 6 Form 1 Counter (for instrument 3369)

RP-07-105 Canberra LB4200 Calibration - Alpha-Beta Proportional Rev. 6 Form 1 Counter (for instrument 3370)

RP-07-105 Canberra LB4200 Calibration - Alpha-Beta Proportional Rev. 6 Form 1 Counter (for instrument 3371))

RP-07-109 Canberra General iMatic Calibration (for instrument 3471) - Rev. 0 Form 3 (03/18/2021)

RP-07-109 Canberra General iMatic Calibration (for instrument 3536) - Rev. 0 Form 3 (03/16/2021)

RP-07-109 Canberra General iMatic Calibration (for instrument 3612) - Rev. 0 Form 3 (02/22/2021)

RP-07-109 Canberra General iMatic Calibration (for instrument 3613) - Rev. 0 Form 3 (01/28/2021)

RP-07-109 Canberra General iMatic Calibration (for instrument 3611) - Rev. 0 Form 3 (02/16/2021)

RP-07-109 Canberra General iMatic Calibration (for instrument 3625) - Rev. 0 Form 3 (01/27/2021)

RP-07-109 Canberra General iMatic Calibration (for instrument 3626) - Rev. 0 Form 3 (03/15/2021)

Corrective Action 2019-0770 Documents 2020-0291 2020-0772 2021-0532 2021-1358 Miscellaneous Organizational Environment, Safety, Health, & Safeguards (ESH&S) 09/01/2021 Chart 24

Inspection Type Designation Description or Title Revision or Procedure Date Organizational Nuclear Materials Control (Radiological Waste and 10/01/2021 Chart Transportation)

Procedures E41-90 Sampling and Analysis of Low-Level Radioactive Waste Solids Rev. 21 OP-1027271 Operating Procedure for Low-Level Rad Waste Loaders Rev. 7 Training/Testing (U)

QWI 15.1.5 Shipment of Radioactive Waste Rev. 12 QWI 5.1.14 Automated Systems/Programs Control Rev. 31 RMS-21 Classification, Characterization, Packaging, and Preparation of Rev. 24 Low-Level Radioactive Waste and Mixed Waste RMS-23 Low-Level Radioactive Waste Administrative Procedure Rev. 11 RP-07-057 General Procedure for Calibration and Control of Radiation Rev. 24 Protection Instrument Radiation Surveys RP-03-010, Form Plantwide Gamma Surveys for 2020 Rev. 10 1 and Form 2 Radiation Work 21-0006 Equipment Removal in Down Blend Rev. 00 Permits (RWPs) 21-0007 Equipment Removal in Zones 5 & 6 in 14A Rev. 00 21-0048 Package Non-Fissile Excepted Bottles in 55-Gallon Drums for Rev. 00 Future Disposition in TP Solids 21-0060 WS-145 Temporary Operation Rev. 00 LTC-21-19 Health Physics and Radiological Surveillance in High Radiation Rev. 0 Areas LTC-21-22 Routine Entries into Building J and Building J Annex Rev. 0 Self-Assessments RP-13-003, Radiation Protection/Health Physics Quarterly Audits: 4th Rev. 13 for Forms 1, 2, and 3 Quarter 2020; 1st, 2nd, 3rd Quarter 2021 Forms 1 & 3, Rev. 14 for Form 2 88045 Corrective Action 2020-1221 Documents Drawings STEC5_1013E BWXT NOG-L and LTC D and D Oversight Areas Rev. 5 STEC9_1000E Contaminated Site Plan Rev. 10 Engineering NMCTWR 21-010 Evaluation of DOT Regulations and Reporting Requirements Rev. 0 Evaluations Related to the Bay 12A Saw Incident RPTWR 18-014 Review of Radiation Protection Monitoring Well Data and Rev. 0 Related Subjects 25

Inspection Type Designation Description or Title Revision or Procedure Date RPTWR 18-017 Filtration and Sampling Issues for NOG-L Shallow Monitoring Rev. 0 Wells RWTWR 18-018 FEP 1 Monitoring Well Uranium Excursion, Actions, and Rev. 1 Evaluation Miscellaneous EA-GEL-2021 BWXT Supplier Quality Audit Report Rev. 0 07 EA-NMIS-21 BWXT Supplier Quality Audit Report Rev. 0 14 N/A 2020/2021 Elevated Environmental Vegetation Sample #4 Rev. 0 Evaluation N/A Semi-Annual Effluent Monitoring Report 08/24/2021 N/A Semi-Annual-Effluent Monitoring Report 02/19/2021 N/A Waste Sample Results from GEL Laboratories 11/24/2020, 04/26/2021, 07/14/2021 N/A Pressure Differentials Across HEPA Filter (various) 10/14/2021 N/A Stack Velocity Measurements, SFF 10/14/2021 Stack Velocity Measurements, RECOVERY N/A 2021 Final Liquid Effluent Data N/A 2021 Cooling Tower (Outfall 002) (Storm Water Runoff) liquid effluent measurements N/A 2021 Bryant's Pond (Outfall 003) liquid effluent measurements N/A Secondary Effluent Release Point Sample Analysis Results from July 2020 to October 2021 N/A 2020 Boundary Air Summary N/A 3rd & 4th Quarter 2020 Environmental Samples 1st & 2nd Quarter 2021 Environmental Samples N/A Potable, D.I., and Recycle Water Analysis Results, 07/12/20 to 11/02/21 RSIN 21-0042 3rd Quarter 2021 Elevated Environmental Sampling Review 10/25/2021 Procedures RP-08 Environmental and Effluent Monitoring and Controls Rev. 10 RP-08-003 Sample Collection from Exhaust Stacks and Their Analysis Rev. 29 RP-08-006 Final Liquid Effluent Preparation and Analysis Rev. 18 RP-10-001 Radiation Control Supervisor and Technician Training Rev. 15 26

Inspection Type Designation Description or Title Revision or Procedure Date 88135.02 Corrective Action 2016-0940 Column overflow spill due to DI water left opened on 12/28/2021 Documents evaporator no. 6, incident 07/24/2016 2021-1440 RTR compact special nuclear material content out of 10/21/2021 specification, incident 10/01/2021 2021-1490 Loose hardware identified on shipping container 10/11/2021 Drawings 14AD2_1010 Uranium Extraction (Evap #1) Rev. 12 UPRR-30052 Evaporator 6 P&ID Rev. 6 UPRR-30053 Recovery Evaporators 2, 3, 4, and 5 P&ID Rev. 4 UPRR-30054 Primary Product Columns P&ID Rev. 3 Engineering NCS-2021-105 NCS Safety Concern for Encapsulated Fuel Cutting Event - 11/11/21 Evaluations CA202101568 NCS-2021-108 NCS Safety Concern for Elevated Concentration in Recovery 12/03/2021 Raffinate Waste Tanks per CA202101643 NMCTWR 21-010 Evaluation of DOT Regulations and Reporting Requirements 11/09/21 related to Encapsulated Fuel Cutting Saw Incident Miscellaneous Correspondence Conway, Ken C., BWXT NOG-L - ALARA Committee 10/13/2021 Secretary, letter to ALARA Committee and Health Physicists, BWXT NOG-L, Re: RSIN and Personnel Contamination Report for September 2021 Correspondence Conway, Ken C., BWXT NOG-L - ALARA Committee 10/18/2021 Secretary, letter to ALARA Committee and Health Physicists, BWXT NOG-L, Re: Agenda October 2021 ALARA Meeting Correspondence Conway, Ken C., BWXT NOG-L - ALARA Committee 09/16/2021 Secretary, letter to ALARA Committee and Health Physicists, BWXT NOG-L, Re: ALARA Meeting Minutes from September 16, 2021 Meeting File Correspondence Conway, Ken C., BWXT NOG-L - ALARA Committee 05/12/2021 Secretary, letter to ALARA Committee and Health Physicists, BWXT NOG-L, Re: RSIN and Personnel Contamination Report for April 2021 Correspondence Conway, Ken C., BWXT NOG-L - ALARA Committee 11/29/2021 Secretary, letter to ALARA Committee and Health Physicists, BWXT NOG-L, Re: Agenda Year-End 2021 ALARA Meeting Correspondence Conway, Ken C., BWXT NOG-L - ALARA Committee 10/21/2021 27

Inspection Type Designation Description or Title Revision or Procedure Date Secretary, letter to ALARA Committee and Health Physicists, BWXT NOG-L, Re: ALARA Meeting Minutes from October 21, 2021 Meeting File M2E801580A001 ES-3100 Shipping Package - Drum Assembly Rev. C Memo Memo to File from K. Conway, RP Unit Manager, "Re: Incident 11/09/2021 Data 12A Saw Use" N-606 Critique Waiver Request (CA 2021-1490) 11/11/2021 N-79 Evaluation of Unusual Incident Report for shipping container 11/11/2021 identified with loose hardware N-79 Evaluation of Unusual Incident: SFF WS-300 did not shutdown 11/05/2021 during interlock test of hydrogen detector A3-LEL-T-01 N/A ALARA Meeting - ALARA Data Review Thru September 2021 October (PowerPoint Slides) 2021 N/A Open Safety: ALARA & RSIN Commitments Lists 10/05/2021 N/A ALARA Meeting - ALARA Data Review Thru October 2021 12/02/2021 (PowerPoint Slides)

N/A Open Safety: ALARA Commitments List 11/04/2021 N/A Open Safety: RSIN Commitments List 11/02/2021 N/A Semi-Annual Effluent Monitoring Report 08/24/2021 SAR 15.12 Liquid and Solid Waste Handling Processes in Uranium Rev. 84 Recovery SAR 15.18 SFF Dry-End Processing - SFF Operation Rev. 136 SAR 15.21 Low-Level Radioactive Waste Process Waste Operations Rev. 79 SAR Appx. 15.12 Liquid and Solid Waste Handling Processes in Uranium Rev. 30 Recovery SAR Appx. 15.18 SFF Dry-End Processing - SFF Operation Rev. 69 SAR Appx. 15.21 Low-Level Radioactive Waste Process Waste Operations Rev. 30 Procedures OP-0061121 Primary Evaporator System Rev. 31 OP-0061123 Contactor Evaporator System Rev. 25 OP-0061124 Evaporator #6 Operation Rev. 17 OP-0061242 Recovery Inline Monitor System Rev. 37 OP-1013741 Use of Seals and Process Tags in Uranium Processing Rev. 2 Services 28

Inspection Type Designation Description or Title Revision or Procedure Date Work Orders Job Order (Title CLASSIFIED) 1251506 88135.04 Corrective Action 2017-0268 SAR 15.42 safety control table improvement suggestion, 12/15/2021 Documents incident 02/23/2017 2017-1288 Water trap IROFS for conventional lines 7 and 8 not installed, 11/10/2021 incident 09/26/2017 2017-1331 Water trap IROFS for conventional lines need evaluation, 11/10/2021 incident 10/09/2017 2019-1022 Stacking on transport card exceeded slab height limit on NCS 11/12/2021 posting, incident 07/24/2019 2020-1745 Daily assays for area waste drums not in accordance with 11/12/2021 procedures, incident 12/02/2020 2021-0047 CSB sprinkler relief valve installation remains outstanding, 12/15/2021 incident 01/09/2020 2021-0113 Improvement suggestion for NCS posting 15-42-002, incident 12/15/2021 01/23/2020 2021-0975 Wire seal found broken on automated storage unit poison tray, 11/12/2021 incident 06/28/2021 2021-1208 Sprinkler obstruction is CSB, incident 08/21/2020 12/15/2021 2021-1648 CSB sprinkler header over-pressurized. Incident 12/13/2017 12/15/2021 NCS Posting 15- Conventional Glovebox Rev. 3 34-005 Drawings FMO-040901-1 Evacuation and Recovery System Rev. 1 JJA1_1001 General Arrangement Container Storage Building Floor Plan, Rev. 4 Mezzanine Plan, Sections, and Details LP-2133 Vacuum Storage Chest Rev. 1 LT-3649 Transport Cart Rev. 4 LT-5289 Storage Chamber Insert Rev. 1 LT-6140 Conventional Insert for Vacuum Storage Chest Rev. 1 LT-6997 Vertical Storage Insert Rev. 1 Engineering CHG-10838 Administrative Changes to SAR Appendix 15.34 approved Changes 07/29/2021 CHG-2462 Update SAR 15.42 per SER 16-045 Phase 01 and CA approved 201700261 09/19/2017 29

Inspection Type Designation Description or Title Revision or Procedure Date CHG-3562 Revise SAR 15.42 Appendix in response to CA 201700268 approved 10/23/2017 CHG-5860 Proposed Intermediate Area Change approved 02/14/2019 CHG-5986 M11-F-070 Moderating Log Update approved 03/21/2019 CHG-6098 Physical Removal of Water Trap IROFS approved 03/19/2019 CHG-6269 Intermediate Area Modification approved 04/29/2019 CHG-6559 Change to SAR 15.34 per SER 18-023 (Phase 1), Removal of approved Lines 1 and 4 06/13/2021 CHG-9475 Revise Posting 15-42-001 for Container Storage Racks approved 01/12/2021 CHG-9668 Cleanroom in Container Storage Building approved 02/01/2021 CHG-9795 Changes to SAR 15.42 and SAR Appendix per SER 20-035 approved PH01 01/27/2021 CHG-9861 Update M11-FAWM-001, "Removal and Disposal of Box-Line approved Pre-Filters" 03/09/2021 SER 20-035 Install New Rack in CSF and Modify Row B approved 06/14/2021 Engineering NCS-2017-163 NCS Safety Concern Analysis for Water Trap System for 10/05/2017 Evaluations Conventional Lines 7 and 8 Ventilation NCS-2017-178 NCS Safety Analysis to Delete the Ventilation Water Trap from 10/24/2017 SAR 15.34 and Scenarios Miscellaneous N/A Inspect & Track Inside Electronic Report for Bays 1A and 2A 05/2021 to Hydraulic Pits Smoke Detector Inspection and Interlocks 12/2021 N/A Inspect & Track Inside Electronic Report for Bays 1A and 2A 06/2020 to General Area Smoke Detector Inspection (Annual) 07/2021 N/A Inspect & Track Inside Electronic Report for Bays 1A and 2A 12/2020 to Hydraulic Pits Sprinkler Flow Tests (QTRLY) 09/2021 NCS Posting 15- Conventional Glovebox Rev. 3 34-002 30

Inspection Type Designation Description or Title Revision or Procedure Date NCS Posting 15- Conventional Glovebox Rev. 3 34-003 NCS Posting 15- Residue/Scrap Glovebox Rev. 1 34-004 NCS Posting 15- Storage Unit Rev. 0 34-009 NCS Posting 15- Chest Cart Rev. 0 34-012 NCS Posting 15- Container Storage Racks Rev. 1 42-001 NCS Posting 15- Container Storage Building / Shipping Area Rev. 0 42-002 Procedures M11-B-034 FMO Allowable Stack Height Chart Rev. 0 M11-F-070 U235 and Moderating Materials Control List - Conventional Rev. 13 Line M11-F-072 U235 and Moderating Materials Control List - Residue Rev. 3 Glovebox OP-0100110 Handling Scrap and Waste Rev. 14 OP-1003724 Fuel Manufacturing Operations Areas Safety Controls Rev. 31 OP-1027218 Container Storage Facility Rev. 3 OP-1041311 (Title CLASSIFIED) Rev. 14 OP-1041746 Storage of Material in the CSF Rev. 4 88135.05 Corrective Action 2017-0261 SAR 15.42 safety control table improvement suggestion, 12/15/2021 Documents incident 02/23/2017 2021-1418 SCBA high-pressure hose disconnected (while in use) and 10/09/2021 began to whip and blowdown air cylinder Fire Plans N/A Pre-Fire Plan, Bay 7 - Map Section 6 02/17/2010 N/A Pre-Fire Plan, Bay 5 and 6 Machine Shop - Map Section 5 01/03/2011 N/A Pre-Fire Plan, Bays 8, 9, and 10 - Map Section 8 06/05/2014 Miscellaneous FSR-05 Facility Siting Review 5 - Bays 1A, 4A through 1-A and 12A; Rev. 4 and Bays 2 through 13 Procedures HS-ET-001 Emergency Team Training Rev. 13 88135.19 Drawings UPRR-30118 Trough Dissolver Rev. 4 Engineering CHG-8332 Add South-End P-Trap Drain Header to both High-Level approved 31

Inspection Type Designation Description or Title Revision or Procedure Date Changes Trough Dissolver Enclosures in Recovery 07/21/2020 Miscellaneous SAR 15,05 High-Level Dissolution Process in Uranium Recovery Rev. 144 SAR 15.18 SFF Dry-End Processing SFF Operation Rev. 136 Procedures OP-1018680 Recovery High-Level Dissolution Rev. 46 QWI 9.1.7 Preventive/Predictive Maintenance and Safety-Related Rev. 12 Controls Testing Program 88135.22 Corrective Action 2021-1555 SFF WS-300 failed to initiate systematic shutdown during 11/19/2021 Documents interlock test of FAS detector A3-LEL-T-01 (IROFS), incident 11/02/2021 Drawings 14AD2_1004 Uranium Extraction P&ID Rev. 23 14AD2_1005 Uranium Extraction P&ID Rev. 20 UPRR-30152 14A Weigh Columns P&ID Rev. 1 Engineering CHG-11424 Parameter Changes for FAS and OP-1001828 Updates approved Changes 11/11/2021 Engineering NCS-2016-122 Nuclear Criticality Safety Release Supporting NCS Safety 11/03/2016 Evaluations Analysis for Waterline Connection on the Primary and Raffinate Feed Columns Miscellaneous N-353 Safety Class Control Maintenance Extension Form (MP-4181) 11/30/2021 SAR 15.18 SFF Dry-End Processing SFF Operation Rev. 136 SAR 15.5 High-Level Dissolution Process in Uranium Recovery Rev. 144 Procedures OP-0061115 Operating Procedure for Primary Extraction System Rev. 51 OP-1001828 FAS Interlocks and Furnace Testing in SFF Rev. 41 & 42 Work Orders 20292916 Safety Class Inventory Leak Check Valves Recovery (Annual - 11/15/2020 MP4181) 32