ML24289A006

Westinghouse Columbia Fuel Fabrication Facility Integrated Inspection Report 07001151/2024003

ML24289A006
Person / Time
Site:	Westinghouse
Issue date:	10/21/2024
From:	Eric Michel NRC/RGN-II/DFRSS
To:	Stutts R Westinghouse
References
IR 2024003
Download: ML24289A006 (1)

Text

Roy Stutts Site Director, Columbia Fuel Fabrication Facility Westinghouse Electric Company 5801 Bluff Road Hopkins, SC 29061

SUBJECT:

WESTINGHOUSE COLUMBIA FUEL FABRICATION FACILITY - INTEGRATED INSPECTION REPORT 07001151/2024003

Dear Roy Stutts:

This letter refers to the U.S. Nuclear Regulatory Commission (NRC) inspection activities conducted from July 1, 2024, to September 30, 2024, for the Westinghouse Columbia Fuel Fabrication Facility. On August 22 and September 19, 2024, the NRC inspectors discussed the results of these inspections with you. The results of this inspection are documented in the enclosed report. No violations of more than minor significance were identified during this inspection 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, Eric C. Michel, Chief Fuels Oversight Branch 2 Division of Fuels, Radiological Safety, and Security Docket No. 07001151 License No. SNM-1107

Enclosure:

As stated cc w/ encl: Distribution via LISTSERVOctober 21, 2024 Signed by Michel, Eric on 10/21/24

ML24289A006 x Non-Sensitive x Publicly Available x SUNSI Review Sensitive Non-Publicly Available

OFFICE RII/DFRSS RII/DFRSS RII/DFRSS NAME J. Raudabaugh T. Vukovinsky E. Michel DATE 10/15/24 10/16/24 10/21/24

U.S. NUCLEAR REGULATORY COMMISSION Inspection Report

Docket Number: 07001151

License Number: SNM-1107

Report Number: 07001151/2024003

Licensee: Westinghouse Electric Company

Facility: Columbia Fuel Fabrication Facility

Location: Hopkins, SC

Inspection Dates: August 19 - 22, 2024, and September 16 - 19, 2024

Inspectors: J. Raudabaugh, Fuel Facility Inspector T. Shewmaker, Fuel Facility Inspector T. Sippel, Sr. Fuel Facility Inspector C. Taylor, Sr. Fuel Facility Inspector

Approved By: Eric C. Michel, Chief Fuels Oversight Branch 2 Division of Fuels, Radiological Safety, and Security

Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Columbia Fuel Fabrication Facility, in accordance with the fuel cycle facility inspection program. This is the NRCs program for overseeing the safe operation of licensed fuel cycle facilities. Refer to https://www.nrc.gov/materials/fuel-cycle-fac.html for more information.

List of Violations

No violations of more than minor significance were identified.

Additional Tracking Items

Type Issue Number Title Report Section Status URI 07001151/2023004-01 Structural Support and Weld 88072 Closed Modifications for the Hot Oil Expansion Tanks

2 PLANT STATUS

The Westinghouse facility converts uranium hexafluoride (UF6) into uranium dioxide using a wet conversion process and fabricated fuel assemblies for use in commercial nuclear power reactors. During the inspection period, normal production activities were ongoing.

INSPECTION SCOPES

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

SAFETY OPERATIONS

88015 - Nuclear Criticality Safety

The inspectors evaluated selected aspects of the licensees Nuclear Criticality Safety program to verify compliance with selected portions of 10 CFR 70; including 70.24, 70.61, and 70.62; Chapter 6, "Nuclear Criticality Safety (NCS) Program" of the facilitys license application; and applicable licensee procedures.

Criticality Analysis (IP Section 02.01)

The inspectors interviewed licensee staff and reviewed nuclear criticality safety evaluations (CSEs), and supporting criticality safety calculations notes (CNs), to verify compliance with 10 CFR 70 and applicable sections of the license application, including 6.1.1, 6.1.3.1, 6.1.3.2, 6.1.3.4, 6.1.3.5, 6.1.4, 6.1.5 and 6.1.6. Specifically, the inspectors interviewed licensee staff and reviewed the following CSEs:

• CSE-1-K, "ADU Pellet Lines 1-5 Torit Ventilation Systems," Revision (Rev.) 9, including review of credible and non-credible accident sequences, including the basis for why certain sequences were considered non-credible, and items relied on for safety (IROFS) associated with the system

• CSE-5-A, "Ammonium Diuranate (ADU) Bulk Blending System," Rev. 5, including review of the what-if analysis, credible and non-credible accident sequences, including the basis for why certain sequences were considered non-credible

• CSE-15-A, "Waste Treatment Tanks T-1148, 1149 and 1147," Rev. 12, including review of credible and non-credible accident sequences, including the basis for why certain sequences were considered non-credible, and IROFS associated with the system

• CSE-20-D, "Miscellaneous Operations in the Pellet Expansion Area," Rev. 4, including review of the what-if analysis, credible and non-credible accident

3 sequences, including spills and the basis for why certain sequences were considered non-credible

• CN-CRI-05-21, "Spherical and Cylindrical Single Parameter Limits for the Incinerator," Rev. 0, which was reviewed because it contained calculations and information supporting the licensee's evaluation of accident sequences in CSE-20-D

• CN-CRI-06-16, "ADU Bulk Blending study," Rev. 0, which was reviewed because it contained calculations and information supporting the licensee's evaluation of accident sequences and IROFS in CSE-5-A

• CN-CRI-08-19, "Donaldson 4DF16 Torit," Rev. 0, which was reviewed because it contained a variety of calculations and information supporting the licensee's evaluation of criticality accident sequences

• CN-CRI-08-21, "Pelleting Fabricmax Torit," Rev. 1, which was reviewed because it contained a variety of calculations and information supporting the licensee's evaluation of criticality accident sequences in CSE-1-K

• CN-CRI-12-2, "Criticality Safety Calculations for Aqueous Waste Tanks," Rev.

0, which was reviewed because it contained a variety of calculations and information supporting the licensee's evaluation of criticality accident sequences in CSE-15-A

• CN-CRI-21-001-000, "Verification of Nuclear Criticality Safety Code Performance," Rev. 0

• CN-SB-11-35, "Criticality Accident Potential for Ammonium Diuranate (ADU)

Bulk Blending System," Rev. 2, which was reviewed because it contained the event trees supporting the licensee's evaluation of criticality accident sequences in CSE-5-A

• Additionally, the inspectors conducted walkdowns in the areas of these CSEs, and other areas of the plant (e.g., scrap cage)

Criticality Implementation (IP Section 02.02)

The inspectors selected engineered and administrative controls from the licensees integrated safety analysis (ISA) summary to verify proper implementation through review of documentation, plant walkdowns, and operator interviews to verify compliance with 10 CFR 70 and applicable sections of the license application, including 6.1.2. Specifically, the inspectors interviewed licensee staff and reviewed the following controls and management measures:

• IROFS ADUBB-901, a passive engineered moderator control, by observing equipment in the field, interviewing operators, and reviewing Dispatch

1. 249428 and MCP-108151

• IROFS ADUBB-903, an administrative moderator control, by reviewing Dispatch #245046

• IROFS ADUBB-909, a passive engineered moderator control, by observing the equipment in the field and reviewing Dispatch #246596 and #245046

• IROFS ADUBB-913, a passive engineered moderator control, by observing the equipment in the field and reviewing Dispatch #241273

• IROFS BAEMISC-103, a passive engineered volume control, by reviewing Drawing 383F01PI15

• IROFS BAEPIT-102, a passive engineered mass control, by observing the equipment in the field and reviewing Drawing 383F01PI15

4

• IROFS BAEPIT-109, a passive engineered moderator control, by reviewing Drawing 383F01PI15

• IROFS BAEPIT-110, a passive engineered geometry control, by reviewing Drawing 383F01PI15

• IROFS FLOOR-119, a passive engineered geometry control, by observing an operator conduct a surveillance and by reviewing Dispatches #220549 and

1. 228014 (records of past surveillances)

• IROFS VENT-PEL-101-DCs, an administrative mass control, by observing equipment in the field, interviewing operators, and reviewing Dispatch

1. 248492 and COP-829013

• IROFS VENT-PEL-119, an administrative mass control, by observing equipment in the field, interviewing operators, and reviewing Dispatch

1. 248492 and COP-829013

• IROFS VENT-PEL-103-SUPERT, an administrative mass control, by reviewing COP-829013 and COP-829015

• IROFS VENT-PEL-102-DCs, a passive engineered moderator control, by reviewing Dispatch #251316

• IROFS VENT-PEL-105-SUPERT, a passive engineered moderator control, by reviewing Dispatch #248492

• IROFS VENT-PEL-115, an administrative mass control, by interviewing engineers and reviewing Dispatch #229957

• IROFS VENT-901, an administrative mass control, by observing a gamma radiation duct survey and reviewing Dispatch #247043

• IROFS VENT-903, an administrative mass control, by reviewing Dispatches

1. 243819 and #256145

• IROFS VENT-PEL-904, an administrative mass control, by reviewing COP-822521

• IROFS WT-163, an administrative mass control, by reviewing Dispatch

1. 275012

• IROFS WT-164, an administrative mass control, by reviewing Dispatch

1. 275012

• IROFS WT-908, an active engineered mass control, by observing equipment in the field, interviewing operators, and reviewing Dispatch #257570

• IROFS WT-909, an active engineered mass control, by observing equipment in the field, interviewing operators, and reviewing Dispatch #257570

• IROFS WT-910, an administrative mass control, by observing operators in the field and reviewing COP-830111

• IROFS WT-911, an administrative mass control, by observing operators in the field and reviewing COP-830111

• and reviewed IROFS training materials for the bulk blend area

Criticality Operational Oversight (IP Section 02.03)

The inspectors assessed the NCS staffs oversight of plant operators, procedures, and operations of systems involving special nuclear material to verify compliance with 10 CFR 70 and applicable sections of the license application, including 3.6.2, 6.1.9. Specifically, the inspectors performed the following activities:

• interviewed two operators concerning criticality hazards and control methods in the bulk blend area

5

• interviewed an operator concerning criticality hazards and control methods on the chemical side of the plant

• observed a licensee NCS engineer conduct a facility walkthrough assessment (FWA) in the bulk blend area

• reviewed the 2024 annual schedule for FWAs

• reviewed FWAs checklists completed in the second quarter of 2024 and signed off on July 18, 2024, including for:

o "Pelleting - Pellet Grinding / D&V Operator,"

o "SOLX Operator,"

o "Outside URRS,"

o "Pelleting - Powder Prep / Press Operator,"

o "Conversion - Conversion Operations and Various Containers,"

o "Final Assembly (Wash Pit, Assembly Storage and BWR Fuel Bundle Inspection Area, Packing),"

o "URRS Bay Operator,"

o "IFBA FA1," and o "Rods."

• observed a Health Physics technician perform a ventilation gamma survey per ROP-05-62, "Radiation Survey of Ventilation Equipment"

Criticality Programmatic Oversight (IP Section 02.04)

The inspectors reviewed NCS program procedures and audits to verify compliance with 10 CFR 70 and applicable sections of the license application, including 3.4.1, 3.6, 6.1.9.

Specifically, the inspectors interviewed licensee NCS staff and/or reviewed the following documents:

• Dispatch #251316, a work order for a visual inspection of the ducts for accumulations

• Dispatch #247043, a work order for non-destructive assay (NDA) inspection of the ducts for accumulations

• the most recent external audit of the licensee's NCS program which was documented in RAF-106-1-00121, "Audit Report for the SNM-1107 Nuclear Criticality Safety Program," Rev. 0

• the most recent revision to licensee procedure RA-106, "Regulatory Component Audits at the Columbia Fuel Fabrication Facility," dated March 14, 2024

• the most recent revision to licensee procedure RA-301, "Floor Storage of Special Nuclear Material," dated July 28, 2024

Criticality Incident Response and Corrective Action (IP Section 02.05)

The inspectors reviewed the licensees criticality accident alarm system (CAAS) and corrective action program (CAP) to verify compliance with 10 CFR 70 and applicable sections of the license application, including 3.8 and 6.1.8. Specifically, the inspectors reviewed documents, and/or interviewed licensee staff concerning the following:

• recent NCS-related CAP entries: IR-2024-1444, IR-2024-1567, IR-2024-3801, IR-2024-4268, IR-2024-7358, IR-2024-7510, IR-2024-7948, and IR-2024-8601

6

• CAP entries resulting from the external audit of NCS: IR-2024-8776, IR-2024-8778, IR-2024-8779; accessed September 17, 2024

• training material provided by NCS to the emergency response organization about the CAAS (2024 CAAS Training)

• reviewed NSA-TR-06-02, "Westinghouse Criticality Detector Coverage Report, Part 1," Rev. 0

• reviewed NCS-TR-06-06, "Westinghouse Criticality Detector Coverage Report, Part 2," Rev. 1

• walked down the location of CAAS detectors in the mechanical area

• walked down the location of pits and subsurface tanks that may contain fissile material in final assembly

FACILITY SUPPORT

88072 - Plant Modifications (Triennial)

The inspectors conducted an extensive review into the licensees configuration management system for plant modifications to ensure that safety-related systems and components (i.e.,

IROFS or credited safety controls) could adequately perform their intended safety function and that system changes had not adversely impacted plant safety and operability. The inspectors review focused on verifying compliance with the applicable requirements in 10 CFR 70 and the License Application, Chapter 3, "Management Measures.

Selection of Modifications (IP Section 02.01)

Prior to on-site inspection activities, the inspection team leader reviewed licensing documents and held discussions with the licensee to discuss plant modifications in risk-significant areas/processes with the licensee. The inspectors selected the following processes for an in-depth review of historical modifications identified as Configuration Control Forms (CCF):

Calciner System and Off Gas Scrubbers (ISA-3, ADU Conversion System, Lines 1 and 5 and Off Gas Scrubber System)

• CCF 14362, Line 5 Calciner/Scrubber Safety Modifications

• CCF 14383, ADU Line 5 Calciner Safety Upgrades Phase II

• CCF 15343, Line 5 Calciner Discharge Chute Level Transmitter Installation

• CCF 18179, Add Delay Timer

• CCF 19034, Calciner Scrubber Vent Flow Transmitter

• CCF 15038, Line 5 Calciner Piping and Valves

• CCF 15401, Line 5 Calciner/Scrubber Valve Replacement

• CCF 14293, ADU Line Calciner Safety Upgrades Phase I

• CCF 15272, Calciner/Scrubber Burner Management System Upgrades

• CCF 15337, ADU Line 1 Calciner Safety Upgrades Phase I

• CCF 17526, ADU Line 1 Calciner Safety Upgrades Phase II

• CCF 18193, Calciner Line 1 Safety Upgrades

• CCF 19243, Line 1 Duplex Valve Transition Chute

• CCF 20023, Installation of New Hydrogen Headers Across Sintering Furnaces

• CCF 12177, Replace the VFD that powers the first discharge screw on ADU Line 1 calciner with a plain

7

• CCF 19031, Install and Activate SSC ADUCAL-920, ADUCAL-921, and ADUCAL-922 for Line 1

• CCF 22196, Modify Piping to Eductors in slab tank, S-13

• CCF 20340, Move Conversion Line 1 Calciner Rotation Confirmation to the Safety PLC

• CCF 12651, Hot Oil System Fill and Drain Site Preparation

Design Process Review (IP Section 02.02)

For the selected modifications listed above, the inspectors reviewed the design process to verify the licensee followed the applicable configuration management requirements in the license application and 10 CFR 70. Specifically, the inspectors conducted the inspection activities listed below:

• interviewed licensee staff, performed walkdowns, and reviewed configuration management packages and supporting documentation to verify that plant modifications were developed, reviewed, classified, approved, and implemented in accordance with 10 CFR 70.72, Facility Changes and Change Process, and 70.62(d), Management Measures

• interviewed licensee staff, performed walkdowns, and reviewed the ISA, ISA Summary, and safety program information impacted by the modifications to verify compliance with 10 CFR 70.62, 10 CFR 70.72, and the baseline design criteria of 10 CFR 70.64, as applicable

• interviewed licensee staff, performed walkdowns, and reviewed configuration management packages and supporting documentation to verify that safety systems and components impacted by the modification, including interactions with other systems, would perform their intended safety function as described in the ISA and safety program documentation

• interviewed licensee staff, performed walkdowns, and reviewed design information for the selected modifications to verify that design assumptions, including natural phenomena hazards (NPH) analysis and set points for instrumentation and control equipment, were supported by adequate technical basis consistent with the design bases and licensing bases of the facility

• interviewed licensee staff, performed walkdowns, and reviewed documentation to verify the licensee applied management measures to the IROFS affected by the modifications in accordance with 10 CFR 70.62

• interviewed licensee staff, performed walkdowns, and reviewed corrective action documents for plant modification issues, including configuration management audits, to verify compliance with the CAP activities described in Chapter 11 of the license application. The scope of the corrective action review included outstanding design and operational issues for the processes selected for in-depth review

System Condition and Capability Review (IP Section 02.03)

For the selected modifications, the inspectors reviewed the system condition and tested capability to verify they were consistent with the applicable design requirements and licensing basis. Specifically, the inspectors conducted the inspection activities listed below:

8

• performed plant walkdown of calciners and calciner off-gas systems with the Manufacturing Engineering Manager to verify assumptions in the ISA applicable to the modifications were based on actual configuration and operation of the modified processes

• interviews, records reviews, and plant walkdowns were conducted to verify assumptions in the ISA or safety basis applicable to the modification were based on the actual configuration and operation of the modified processes

• performed interviews with control room operators regarding the calciners and calciner off-gas control systems and alarms

• interviews, record reviews and plant walkdowns were conducted to verify management measures were properly implemented to ensure that IROFS or other safety controls were available, capable, and reliable to perform their function when needed

• interviews, record reviews, and plant walkdowns were conducted to verify that administrative controls that involve operator action could be accomplished as assumed in the licensees ISA

• reviewed reference forms, Safety Significant Interlocks, Alarms and Passive Engineered Controls Functionality Verifications Forms for conversion lines 1 and 5 to verify the system established for checking functionality of safety significant interlocks, alarms and passive engineered controls

Post-Modification Testing (IP Section 02.04)

For the selected modifications, the inspectors interviewed licensee staff and reviewed post-modification testing records to determine whether the plant was in a safe configuration during post-modification testing. The inspectors reviewed the following post-modification tests to determine whether post-modification testing ensured adequate implementation of the design and safety system functionality:

ISA 03 ADU Conversion System, Calciner and Scrubber

• Work Order (WO) 661771, 07/28/2014

• WO 671953, 01/30/2015

• WO 709883, 09/24/2015

• WO 804125, 05/16/2018

• WO 871694, 01/13/2020

• WO 703254, 07/27/2015

• WO 706891, 08/27/2015

• WO 812716, 08/07/2018

• WO 806731, 06/07/2018

• WO 658733, 05/15/2014

• WO 661771, 06/13/2014

• WO 598681, 09/24/2012

• WO 871691, 01/13/2020

• WO 706891, 08/27/2015

• Dispatch # 224891, 11/23/2023

Documentation Review (IP Section 02.05)

9 The inspectors reviewed a sample of plant documents impacted by the modifications selected for review to verify the licensee had either updated or was in the process of updating such documents to reflect the modifications in accordance with the license application requirements and 10 CFR 70.72. Additionally, the inspectors followed-up on Unresolved Item (URI) 70-1151/2023-004-01, "Structural Support and Weld Modifications for the Hot Oil Expansion Tanks." The inspection sample included:

• COP-810901, Calcination, Rev. 58

• COP-810806, Calciner Feed Screw, Rev. 8

• COP-811101, Calciner Off-Gas Scrubber, Rev. 91

• MCP-202241, Calciner Scrubber Off-Gas Vent Hood Flow Transmitter, FCI FS101, Rev. 2

• TA-500, Configuration Control Program, Rev. 42

• ISA Chapter 03, ADU Conversion System, Rev 18

• Criticality Safety Evaluations (CSE) o CSE-3-I, Criticality Safety Evaluation for ADU Conversion Calciner, Rev.7 o CSE-03-H, Conversion Lines Oil Dryers and Bucket Elevators, Rev.3 o CSE-8-C, ADU and Erbia Pellet Sintering Lines, Rev. 12

• CF-81-101, Conversion ICM Verification Log, 11/30/2023

• RA-108, Safety Significant Controls, Rev.32

• FA-106, Installation Instructions, Rev.15

• FA-114, Independent Technical Reviews, Rev.4

• RAF-409-1, Pre-Startup Safety Review (ECN 18193), 6/4/18

• training changes under CCF 19030, 1st -3rd Shift, 01/23/2020

• training qualifications for process engineers to verify current training for individual who develops and reviews configuration management packages

• work instructions for CCF 20023, Hydrogen System Purge, New Header Installation

• ITR for CCF-19031 to Activate SSC ADUCAL-920, ADUCAL-921, and ADUCAL-922 for Line 1 dated 09/10/2019

• Reportability Evaluation CAF-07-112023-11929, Conversion Hot Oil Expansion Tanks Weld Issue, dated 04/29/24

INSPECTION RESULTS

Minor Violation 88072 Structural Support and Weld Modifications for the Hot Oil Expansion Tanks

Minor Violation: Inspectors identified one minor violation of 10 CFR 70.72 Facility Change and Change Process. On November 2023, NRC inspectors identified that hot oil expansion tank support beams located in the ceiling of the Conversion Area over the Hot Oil Room were not welded to the building structural steel in accordance with DWG. 651FO1STO1, Expansion Tank Support Detail. Unresolved Item (URI) 70-1151/2023-004-01, "Structural Support and Weld Modifications for the Hot Oil Expansion Tanks," was opened in inspection report 70-1151/2023-004 to track the licensee's review and evaluation of the identified issue.

Screening: The inspectors determined the violation was minor. Procedure, TA-500, Columbia Manufacturing Plant Configuration Control, Rev 27, implements the requirements for facility changes. Contrary to the above, the procedure failed to adequately provide

10 guidance on walkdown requirements for facility changes. Specifically, in November 2023, inspectors identified that hot oil expansion tank support beams located in the ceiling of the Conversion Area over the Hot Oil Room were not welded to the building structural steel in accordance with DWG. 651FO1STO1, Expansion Tank Support Detail. The initial modification and associated welding took place in 2013. Upon discovery, the licensee took immediate corrective actions to weld the beams in accordance with design DWG.

651FO1STO1. The licensee created work order Dispatch # 224891, and the hot oil expansion support beams were welded to the roof structural steel on December 23, 2023.

Inspectors determined the violation was minor and aligned most closely with Example 1d, using the screening criteria in Appendix B, Examples of Minor Violations in Inspection Manual Chapter (IMC) 0616. The issue was a minor violation because an internal evaluation showed that in an event of a single tank or double tank failure due to seismic or other severe events, there would be limited penetration of the tank into the Hot Oil Room concrete slab roof (IROFS - ADUHOS-906s function is to provide a 1.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> fire barrier in the event of a fire) and localized cracking and deformation on the roof concrete structure. NRC inspectors reviewed Engineering Calculation Note GES-2500-CN-SSQ-000001, Impact of an Expansion Tank Fall on Floor Slab in the Columbia Fuel Fabrication Facility dated December 15, 2023, and determined the evaluation confirmed the barrier roof dike would continue to contain hot oil with no adverse nuclear or radiological safety impact on equipment and or personnel. Inspectors reviewed the licensee's extent of condition (LTR-EHS-24-43) dated August 12, 2024, and determined this was an isolated issue as no other similar tank configurations were identified on-site. The issue was entered into the licensee CAP as CR 2023-11929. URI 70-1151/2023-004-01, "Structural Support and Weld Modifications for the Hot Oil Expansion Tanks, is considered closed to this minor violation, with no further action needed.

Enforcement: This failure to comply with 10 CFR 70.72 Facility Change and Change Process" 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 September 19, 2024, the inspectors presented the integrated inspection results to Roy Stutts and other members of the licensee staff.

• On August 22, 2024, the inspectors presented the Permanent Plant Modifications Triennial inspection results to Roy Stutts and other members of the licensee staff.

11 DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or Procedure Date 88015 Corrective Action IR-2024-9843, IR-CAP entries documenting NRC identified issues 09/18/2024 Documents 2024-9856 Resulting from Inspection Drawings 301F01PI03 Solvent Extraction / UNH Purification Aqueous Waste Rev. 37 System 383F01PI15 Freight Elevator Rev. 3 Engineering CN-CRI-05-21 Spherical and Cylindrical Single Parameter Limits for the Rev. 0 Evaluations Incinerator CN-CRI-06-16 ADU Bulk Blending study Rev. 0 CN-CRI-06-9 Integrated Fuel Burnable Absorber (IFBA) Pellet Coaters Rev. 0 CN-CRI-08-19 Donaldson 4DF16 Torit Rev. 0 CN-CRI-08-21 Pelleting Fabricmax Torit Rev. 1 CN-CRI-12-2 "Criticality Safety Calculations for Aqueous Waste Tanks Rev. 0 CN-CRI-14-005 Incinerator Polishing Filters Rev. 0 CN-CRI-20-003 NCS Manual Rev. 9 NCS-007 and NCS-013 CN-SB-11-033-Criticality Accident Potential for Waste Treatment Tanks T-Rev. 6 006 1148, T-1149, T-1147 CSE-1-K ADU Pellet Lines 1-5 Torit Ventilation Systems Rev. 9 CSE-15-A Waste Treatment Tanks T-1148, T-1149, and T-1147 Rev. 12 Miscellaneous 2024 CAAS Training material provided to the Emergency Response Training Organization by the NCS organization about the CAAS used at Westinghouse Procedures COP-814749 Cleaning Bulk Containers Rev. 23 COP-814750 Bulk Blending Equipment Cleanout Rev. 34 COP-822521 Pellet Area Fabricmax Dust Collector and Inspection Hood Rev. 16 Ventilation COP-829013 Functional Verification of Safety Significant Controls Pallet Rev. 77 Area COP-829015 Super Torit Dust Collection - Startup, Operation, and Rev. 12

12 Inspection Type Designation Description or Title Revision or Procedure Date Shutdown COP-830111 SOLX and Product Concentrator System 2 - Startup and Rev. 35 Operation COP-830210 Incinerator Operation Rev. 58 MCP-108151 ADU Bulk Blending Container Inspection and Repair CriteriaRev. 5 PM86700 ERBIA ELEVATOR PIT INTERLOCKS AND ALARMS - 52 WEEK PM RA-106 Regulatory Component Audits at the Columbia Fuel Rev. 46 Fabrication Facility RA-301 Floor Storage of Special Nuclear Material Rev. 28, dated 07/18/2024 RA-303 Control of Moderating Materials for Nuclear Criticality SafetyRev. 19 RAF-316-1 Nuclear Criticality Safety Checklist for NCS Facility Rev. 6 Walkthrough Assessments ROP-05-062 Radiation Survey of Ventilation Equipment Rev. 24 Self-Assessments RAF-106-1-00121 Audit Report for the SNM-1107 Nuclear Criticality Safety Rev. 0 Program Work Orders Dispatch #212738 52 Weeks PM85125 SI-Safety, Process Water Backflow 10/24/2023 Preventer Verification Dispatch #216844 52 Weeks OM85016 SI-Safety Interlocks, Incinerator 11/09/2023 Dispatch #218542 52 Weeks PM8512 SI-Safety, Process Water Backflow 11/23/2023 Preventer Verification Dispatch #220549 52 Weeks OM91007d SI-SAFETY, CHEMICAL AREA Completed FLOOR INSPECTION - 52 WEEK OM 12/12/2023 Dispatch #228014 52 Weeks PM20327 SI-SAFETY, CHEMICAL AREA FLOOR Completed INSPECTION - 52 WEEK PM 01/11/2024 Dispatch #229957 26 Weeks OM82004 SI-Safety, Ventilation Duct Inspection, 01/25/2024 ADU Pelleting Dispatch #241273 13 weeks PM 81036 SI-Safety Bulk Blending Cart Lift 03/20/2024 Dispatch #243623 52 Weeks OM81505 SI-Safety, T-1147 Passive Overflow 04/01/2024 Verification Dispatch #243819 13 Weeks OM75015 SI Safety, Rod Repair Torit Dust 04/28/2024 Collector

13 Inspection Type Designation Description or Title Revision or Procedure Date Dispatch #245046 4 Weeks (Monthly) PM20133 SI-SAFETY, FORK LIFT Completed TRUCK` 04/08/2024 Dispatch #246596 13 Weeks PM20128 SI-SAFETY, ELETRIC LIFT TRUCK Completed 04/16/2024 Dispatch #247043 4 Weeks (Monthly) OM91009 SI-Safety, HP Ventilation 04/18/2024 Survey Dispatch #248492 52 Weeks OM8200a SI-Safety, Safety Significant Control 04/26/2024 Checks, Pellet Lines Dispatch #249428 26 Weeks PL81070 SI-SAFETY, BULK CONTAINER Completed INSPECTION 05/01/2024 Dispatch #251316 52 Weeks OM82230 SI-Safety, Ventilation Duct Integrity 04/29/2024 Inspection Dispatch #257570 52 Weeks OM85022 SI-Safety Interlocks, Solvent Extraction06/10/2024 Dispatch #269630 13 Weeks OM85029 SI-Safety, URRS Tank Inspection (T- 08/12/2024 1148)

Dispatch #271812 13 Weeks OM85029 SI-Safety, URRS Tank Inspection (T- 08/19/2024 1149)

Dispatch #275012 52 Weeks OM85092 SI-Safety, URRS Tank Inspection (T- 09/09/2024 1147) 88072 Calculations GES-2500-CN-CFFF Expansion Tanks (BUD122640) Rev. 0 SSQ-000001 Corrective Action CR 2023-0520 High Roof Effluent-Conversion Line 3 and 4 01/18/2023 Documents CR 2023-5738 Conversion Line 5 High Calciner Pressure - Lost of Seal 05/23/2024 GER-2024-73 Recordable Injury 05/30/2024 IR-2023-10277 Roof Effluent Sample 10/17/2023 IR-2023-11666 Calciner Steam Blowdown Valve Failed Testing 11/23/2023 IR-2024-5872 Conversion Line Flapper Valve Failure 05/29/2024 IR-2024-5912 First Aid Injury 05/30/2024 IR-2024-6031 Recordable Injury 06/03/2024 IR-2024-8131 Audit-Conversion Hot Oil Expansion Tanks - Evaluation of 08/01/2024 Potential Impact from a Fall of the Hot Oil Expansion Tanks and Built-up Beams onto the Hot Oil Room Roof/Mezzanine Corrective Action IR 2023-11929 Conversion Hot Oil Expansion Tanks-Evaluation of Potential 11/20/2023 Documents Impact from a Fall of the Hot Oil Expansion Tank and Built-

14 Inspection Type Designation Description or Title Revision or Procedure Date Resulting from Up Beams onto the Hot Oil Room Inspection LTR-EHS-24-43 Extent of Condition Review for Corrective Action Program 08/12/2024 Issue Report 2023-11929 (IR-2023-11929)

Drawings 334A01LS09, FIC-109C Flow To Calciner Rev. C1 sheet 5 334F05PI01, Line #1 / Calcination Rev. C1 sheet 2 334F05PI02, Line 1 Calcination, Calciner Scrubber and Filters Rev. 51, C1 sheet 1 334F05PI02, Line 1 Calcination, Calciner Scrubber and Filters Rev. 51, C1 sheet 2 334F05PI02, Line 1 Calcination, Calciner Scrubber and Filters Rev. 30, C1 sheet 3 338A01LS36, N2 Flow to Calciner Rev. C2 sheet 2 338A01LS37, Steam Flow to Calciner Rev. C2 sheet 2 338A01LS38, Hydrogen Flow to Calciner Rev. C2 Sheet 2 338A05LS02, Scrubber Pressure Control Rev. C2 sheet 3 338F05PI02, Line 5 Calcination, Calciner Scrubber and Filters Rev. 54, C1 sheet 1 338F05PI02, Line 5 Calcination, Calciner Scrubber and Filters Rev. 55, C1 sheet 2 338F05PI02, Line 5 Calcination, Calciner Scrubber and Filters Rev. 29, C1 sheet 3 Engineering CSE-3-1 Criticality Safety Evaluation (CSE) for the Columbia Fuel Rev. 9 Evaluations Fabrication Facility ADU Conversion Calciner GEM 1391352-Revalidation of the Process Hazard analysis of the ADU 05/2005 545-04 Conversion Process at the Westinghouse Nuclear Fuels Facility ITR-19031-1 ITR for CCF-19-031 to Activate SSC ADUCAL-920, 09/10/2019 ADUCAL-921, and ADUCAL-922 for Line 1

15 Inspection Type Designation Description or Title Revision or Procedure Date PSEDoc-0001283 Engineering Review #13218 Calciner Safety Upgrade 11/26/2013 PSEDoc-0001989 Line 5 Calciner Combustion Safety Control Upgrades 06/23/2014 PSEDoc-0002119 Approval for CCF 14362 Prework 11/26/2013 PSEDoc-0002121 ITR for Conversion Line 5 Calciner Safety Upgrades 09/11/2014 PSEDoc-0002140 ITR for CCF 14362 Line 5 Calciner Safety Upgrades Phase 2 09/09/2014 PSEDoc-0002543 CCF15272 Line 1 Calciner Burner Management Upgrades 06/13/2015 ITR PSEDoc-0002623 ITR of Line 1 Calciner Combustion Safeguard Modification 08/18/2015 PSEDoc-0002656 CCF15401 ITR for Removal of Spring-open Valves on Line 5 09/08/2015 PSEDoc-0004754 RAF-104-10 Calciner Line 1 Safety Upgrades 10/18/2016 PSEDoc-0004846 ITR for Conversion Line 1 Calciner Safety Upgrades 05/22/2018 PSEDoc-0004905 CCF 18193 Pressure Test Report for Calciner Line 1 Safety 06/06/2018 Upgrades PSEDoc-0004917 Hydrogen Piping Pressure Test Report 06/07/2018 PSEDoc-0011323 Risk Assessment Board Minutes August 13, 2024 08/13/2024 PSEDoc-0011386 Design Review Screening Form CCF-D-24157 08/19/2024 Miscellaneous CAF-07-112023-Reportability Evaluation-Conversion Hot Oil Expansion 04/29/2024 11929 Tanks Weld Issue CCF 15272 Line 1 Calciner/Scrubber Burner Management System 06/02/2015 Upgrades CF-81-932 Safety Significant Interlocks, Alarms and Passive Engineered Rev. 74 Controls CF-81-955 Blending and Scrap Cage Interlocks Listing Rev. 135 CF-81-955 ADU Conversion Blending and Scrap Cage Interlocks Listing Rev. 135 Sketch 815417-4 Dryer/Calciner Safety Significant Controls Rev. 34 Sketch 815417-5 Scrubber and Powder Discharge Systems Safety Significant Rev. 34, 35 Controls Sketch 815417-9 Chemistry Operating Procedure Sketch Conversion Area Rev. 50, 59, 60, 61 Procedures CF-81-651 Line 5 Scrubber Slab Tank Lockout/Tagout Rev. 3, 4 CN-SB-12-015 Criticality Accident Potential for the ADU Conversion CalcinerRev. 4 COP-810704 Chemical Operating Procedure Conversion & Scrap Rev. 8 Reprocessing Area

16 Inspection Type Designation Description or Title Revision or Procedure Date COP-810901 Conversion and Scrap Processing Areas Rev. 49 COP-811101 Calciner Off-Gas Scrubber Rev. 91 COP-811121 Clearing Blockages in the Calciner Off-Gas System Rev. 38 COP-910806 Calciner Feed Screw Rev. 8 FAF-114 Independent Technical Reviews Rev. 4 ISA Summary - ADU Conversion System Rev. 19 ISA 03 MCP-108139 Mechanical Equipment Substitution Rev. 5 MCP-202174 Electrical and Instrument Equipment Substitution Rev. 34 MCP-203328 Verification of Interlock ADUCAL-901 Rev. 5 QA-006 Computer Software Quality Assurance Rev. 55 QA-007 PLC Quality Assurance Rev. 24 RA-104 Regulatory Review of Configuration Change Authorization Rev. 27, 30, 36 RA-108 Safety Significant Controls Rev. 32 TA-500 Columbia Manufacturing Plant Configuration Control Rev. 28, 29, 37, 42 TA-500-10 Configuration Management Risk Assessment Board Meeting Rev. 4 TA-500-11 Facility Change Request Control Procedure Rev. 0 TA-500-9 Electronic Configuration Change Life Cycles 01/21/2022 WM-008 Work Management Planning Rev 2 WM-008 Work Order Planning Rev.6 Radiation ROF-07-001-2 Check List for Health Physics Response to Contaminated 05/30/2024 Surveys Injury Self-Assessments EHS-Audit-24-8 Regulatory Component Audit for Configuration Management; Audits and Records Management Work Orders 598681 Remove VFD from Calciner discharge screw and replace 09/24/2012 with contactor according to drawings that are linked in the CCF 658733 SI-Safety, Hi Temperature Shutoff PM 05/15/2024 661771 Line 5 Calciner Burner Interlock Checks 06/13/14 671953 Interlock checks Line 5 upgrade 09/19/2014 703254 Post Modification - Complete Interlock Checks 07/27/2015

17 Inspection Type Designation Description or Title Revision or Procedure Date 706891 Post Modification - Perform Function Verification of SSCs- 08/27/2015 CCF-15337 806731 Perform Interlock Checks 06/07/2018 812716 Calibration of SIS transmitters for Line 1 Calciner upgrades08/07/2018 871691 Functional Testing for ADUCAL-920, ADUCAL-921-and 01/13/2020 ADUCAL-922 CCF 12651 Hot Oil System Fill and Drain Site Preparation Dispatch # Weld Beams holding up Hot Oil Expansion tanks per original 12/23/2023 224891 drawing 651F01ST01 sheet 01

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