ML25337A329
| ML25337A329 | |
| Person / Time | |
|---|---|
| Site: | BWX Technologies |
| Issue date: | 12/08/2025 |
| From: | Eric Michel NRC/RGN-II/DFRSS/FOB2 |
| To: | Markle H BWXT |
| References | |
| IR 2025003 | |
| Download: ML25337A329 (0) | |
Text
Howard Markle Vice President and General Manager Nuclear Operations Group, Inc.
BWXT Nuclear Operations Group, Inc.
P.O. Box 785 Lynchburg, VA 24505-0785
SUBJECT:
BWXT NUCLEAR OPERATIONS GROUP, INC. - INTEGRATED INSPECTION REPORT 07000027/2025003
Dear Howard Markle:
This letter refers to the Nuclear Regulatory Commission inspection activities conducted from July 1 to September 30, 2025, at the BWXT Nuclear Operations Group, Inc. Lynchburg facility.
On December 1, 2025, the NRC inspectors discussed the results of this inspection with 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.
Due to the temporary cessation of government operations, which commenced on October 01, 2025, the NRC began operating under its Office of Management and Budget-approved plan for operations during a lapse in appropriations. Consistent with that plan, the NRC operated at reduced staffing levels throughout the duration of the shutdown. However, the NRC continued to perform critical health and safety functions. On November 13, 2025, following the passage of a continuing resolution, the NRC resumed normal operations. However, due to the 43-day lapse in normal operations, the Office of Nuclear Materials Safety and Safeguards granted the Regional Offices an extension on the issuance of the calendar year 2025, 3rd quarter integrated inspection reports normally issued by November 15, 2025, to December 31, 2025. The NRC will resume the routine cycle of issuing inspection reports on a quarterly basis beginning with the calendar year 2025, 4th quarter integrated inspection reports, which will be issued 45 days after the 4th quarter ends on December 31, 2025.
December 8, 2025
H. Markle 2
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. 07000027 License No. SNM-42
Enclosure:
As stated cc w/ encl: Distribution via LISTSERV Signed by Michel, Eric on 12/08/25
SUNSI Review X
Non-Sensitive
Sensitive X
Publicly Available
Non-Publicly Available OFFICE RII/DFRSS RII/DFRSS RII/DFRSS RII/DFRSS NAME M. Doyle C. Oelstrom N. Pitoniak E. Michel DATE 12/08/2025 12/08/2025 12/08/2025 12/08/2025
Enclosure U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number:
07000027 License Number:
SNM-42 Report Number:
07000027/2025003 Enterprise Identifier:
I-2025-003-0034 Licensee:
Nuclear Operations Group, Inc.
Facility:
BWXT Nuclear Operations Group, Inc.
Location:
Lynchburg, VA Inspection Dates:
July 01, 2025 to September 30, 2025 Inspectors:
M. Doyle, Senior Resident Inspector N. Peterka, Branch Chief (acting)
T. Sippel, Sr. Fuel Facility Project Inspector Approved By:
Eric C. Michel, Chief Fuels Oversight Branch 2 Division of Fuels, Radiological Safety, and Security
2
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at BWXT Nuclear Operations Group, Inc.,
in accordance with the fuel cycle facility inspection program. This is the NRCs program for overseeing the safe operation of licensed fuel cycle facilities. Refer to https://www.nrc.gov/materials/fuel-cycle-fac.html for more information.
List of Violations No violations of more than minor significance were identified.
Additional Tracking Items Type Issue Number Title Report Section Status URI 07000027/2025001-01 Sealand Accumulation 88015 Closed
3 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 88015 - Nuclear Criticality Safety The inspectors evaluated selected aspects of the licensees Nuclear Criticality 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 70.24, 70.50, 70.61, 70.62, and Appendix A, Chapter 5, Nuclear Criticality Safety, 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 (NCSEs), and associated supporting documents/assumptions and calculations, to verify compliance with 10 CFR 70 and applicable sections of the license application, including 5.1, 5.2, 5.3, 5.3.1.2, and 5.3.1.3. Specifically, the inspectors interviewed licensee staff and reviewed the following:
NCS-PA-21-00001, "Nuclear Criticality Safety Evaluation of the Waste Treatment Facility (WTF) Low Level Radioactive (LLR) Waste Process," Rev.
2, including assumptions accident sequences (e.g., WTF-1)
NCS-PA-21-00002, "Nuclear Criticality Safety Evaluation of Low Level Radioactive Dry Waste Processes," Rev. 3, including the review of accident sequences related to the Decontamination Area (e.g., TRNSFR1-2, TRNSFR1-3, TRNSFR1-4)
NCS-PA-27-00003, "Nuclear Criticality Safety Evaluation of Dry Horizontal Operations with Discrete NR Fuel Elements," Rev., including a review of what-if analysis, normal, and credible abnormal accident sequences (e.g., HEW-2, HEW-4, HEW-5)
4 NCS-2012-004, "NCS Safety Analysis for the Hot Waste Drain Lines -
CA200800449," dated June 7, 2012, including the review of the bounding conditions modeled in the analysis of upset conditions NCS-2015-103, "NCS Safety Analysis Supporting SER 15-030 Phase 01 thru Phase 03 - S1B Qualification Fillers Fabrication, Pack Assembly and Element Fabrication," dated 10/28/2015, which was reviewed because it contained a variety of calculations and information supporting the licensee's evaluation of accident sequences and items relied on for safety (IROFS) in NCS-PA 00003 NCS-2018-047, "NCS Safety Analysis Supporting SER 17-063 Phase 01 Higher Loaded VTC Packs, Elements, and Met. Lab Samples," dated 05/29/2018, which was reviewed because it contained a variety of calculations and information supporting the licensee's evaluation of accident sequences and IROFS in NCS-PA-27-00003 NCS-TR-00020, "Nuclear Criticality Safety Calculations for Low Level Radioactive Waste Processing Activities," Rev. 1, which was reviewed because it contained a variety of calculations and information supporting the licensee's evaluation of accident sequences and IROFS in NCS-PA-21-00001 and NCS-PA-21-00002 NCS-TR-00026, "Nuclear Criticality Safety Calculations for the Waste Treatment Facility (WTF) Low Level Radioactive (LLR) Waste Process," Rev.
1, which was reviewed because it contained a variety of calculations and information supporting the licensee's evaluation of accident sequences and IROFS in NCS-PA-21-00001 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 a review of process and system descriptions, plant walkdowns, and operator interviews to verify compliance with 10 CFR 70 and applicable sections of the license application, including 5.2, 11.4.3 and 11.4.4. Specifically, the inspectors interviewed licensee staff and reviewed the following controls, and their management measures, associated with the NCSEs listed above and selected areas in Safety Analysis Report (SAR) 15.21 and 15.27:
Active engineered concentration control IROFS, in the Retention Tank Building, including review of a calibrations record Administrative mass control IROFS in the Chem Lab Area, and OP-1004074, NCS Posting 15-29-001 and area logbook Q2-171 Administrative spacing control IROFS in the Chem Lab Laboratory Area, and NCS Posting 15-29-001 Active engineered concentration control IROFS for the Hot Waste Drains in the Chem Lab, and OP-1004605 and logbook Q2-206 Administrative concentration control IROFS for the Hot Waste Drains in the Chem Lab, and OP-1004605 Administrative mass control IROFS in the Decontamination Area, and associated NCS Posting 15-21-012
5 Administrative spacing control IROFS in the Decontamination Area, and associated NCS Posting 15-21-012 Administrative moderator control IROFS in the Decontamination Area, and associated NCS Posting 15-21-012 Administrative geometry control IROFS in for the Element Workstations in various production bays, and associated NCS Posting 15-27-083, 15-27-039, and 15-37-014 Administrative moderator controls IROFS in for the Element Workstations in various production bays, and associated NCS Posting 15-27-083, 15-27-039, and 15-37-014 Administrative spacing control IROFS in for the Element Workstations in various production bays, and associated NCS Posting 15-27-083, 15-27-039, and 15-37-014 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 5.5, 11.3, 11.5.1.1, 11.5.1.2 and 11.5.3.1. Specifically, the inspectors performed the following activities:
interviewed retention tank building staff concerning criticality hazards and control methods, including monitoring for long term accumulations interviewed NCS engineers about monitoring for long term accumulation in the retention tank building and the met lab sludge tanks observed a trainee NCS engineer conduct a weekly NCS inspection under the supervision of a fully qualified licensee NCS engineer, and reviewed selected Nuclear Criticality Safety Inspection Forms documenting recent weekly NCS inspections reviewed a sample of weekly NCS inspections and the "Audits, Inspections and Observations Summary" for the 1st and 2nd quarters of calendar year 2025 interviewed retention tank building personnel, laboratory personnel, element workstation personnel, and other operators concerning criticality hazards and control methods Criticality Programmatic Oversight (IP Section 02.04)
The inspectors reviewed NCS program procedures, and NCS staff qualifications to verify compliance with 10 CFR 70 and applicable sections of the license application, including 2.1.6 and 11.4.1. Specifically, the inspectors interviewed licensee NCS staff and reviewed the following documents:
discussed training and qualification status of the most recently hired criticality safety engineers with management and reviewed applicable qualification documentation the most recent revision to licensee procedure NCSE-02 Attachment 1, "NCS Process Analysis (PA) Writer's Guide," Rev. 2
6 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 5.5.1, 5.6 and 11.6. Additionally, the inspectors followed up on Unresolved Item (URI) 07000027/2025001-01 related to the accumulation of uranium in a sealand container. Specifically, the inspectors:
reviewed Nuclear Safety Concerns (listed below) for recent NCS-related events from associated CAP entries reviewed NCS-2025-016, "NCS Safety Concern for Legacy Equipment at Waste Treatment - CA202500336," dated April 16, 2025, including review of calculation assumptions and input files reviewed recent NCS evacuation drill records and performance for 2024, interviewed licensee staff about how to safely evacuate and licensee emergency personnel about evacuation training and performance, and walked down selected evacuation routes reviewed RTP-August-2025: Emergency Evacuation reviewed position specific emergency response training for NCS Coordinators, and interviewed NCS and emergency response personnel about criticality event response discussed with licensee staff the ongoing work to update the BWXT NOG-L CAAS, including revised detector placement calculations and installation of additional detectors as needed reviewed portions of the detector placement calculation PSI-RP-24-007, "Criticality Accident Alarm System Analyses: NOG-L Retention Tank Area" 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.
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:
On August 22,2025, the inspector verified all required postings were posted on regulatory boards 1, 2, and 3
7 Radiation Work Permit (RWP) (IP Section 03.09)
The inspectors reviewed and observed the radiation work permit (RWP) 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 2025-0048, Demolition of old cyclone enclosure, conducted on July 1, and 3, 2025 88135.04 - Resident Inspection Program Operational Safety The inspectors evaluated whether the material condition and as-found configuration of selected site structures, systems, and components, documentation, personnel, and IROFS to verify compliance with 10 CFR Part 70, the license, 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 SAR15.42, Container Storage Facility:
The inspector performed a walkdown of the Container Storage Facility, management measures, and IROFS with an Operations frontline manager responsible for SAR 15.42 The inspector reviewed corrective action documents associated with SAR 15.42 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 verify compliance with the fire protection program as described in Chapter 7, Fire Safety of the license application, and the National Fire Protection Association (NFPA) 801, Standard for Fire Protection for Facilities Handling Radioactive Materials, as required.
Fire Area Walkdown (IP Section 03.01)
The inspectors walked down and evaluated the fire area listed below:
bay 17 on September 17, 2025 88135.19 - Post Maintenance Testing The inspectors evaluated post-maintenance test activities to verify compliance with license application Chapter 11, Management Measures, and test procedures and/or work order (WO) instructions to confirm functional capability of the IROFS and/or safety controls following maintenance.
8 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.
Work order 20393936, primary scrub feed pump (IROFS SAR 15.05) replacement, and functional test and leak check on 07/31/2025 Work order 20393986, Replacement of Complexing Columns leak test on 07/31/2025 88135.22 - Surveillance Testing The inspectors evaluated IROFS and safety controls that required periodic surveillance and/or calibration tests to ensure they were available and reliable to perform their function when needed, to comply with license application Chapter 11, Management Measures, and the performance requirements of 10 CFR 70.61 and 70.62, and to maintain their operational readiness consistent with the Integrated Safety Analysis.
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.
The inspector observed the mixing study and vessel calibration/volume check surveillance for uranium recovery complexing columns on August 14, 2025.
The inspector observed the weekly nuclear criticality safety (NCS) inspection of SAR 15.5 in uranium recovery by an NCS engineer on September 03, 2025.
INSPECTION RESULTS URI Sealand Accumulation URI 07000027/2025001-01 88015
==
Description:==
On January 22, during activities to clean up legacy waste across the site, a sealand storage container containing legacy contaminated waste was moved from outside the Waste Treatment Facility into the decontamination facility. During the move the waste in the sealand shifted unexpectedly, which allowed better measurements of the contents. Of particular note was a large cutting or milling machine with an integrated 'cutting fluid' reservoir at the bottom. Based on measurements made using hand-held radiation detectors, the amount of uranium (U)-235 in this reservoir was estimated to be less than 50 grams. This was higher than the amount of material that was previously believed to be present.
As a result, Security and NCS were informed and security compensatory measures imposed.
The contents of the sealand were emptied, bottled or drummed, and decontaminated to the extent practical under NCS controls in the decontamination facility. The bottles and drums of material collected were sent to the drum count facility for counting from January 31 to
9 February 18, 2025. A total count of 686.39 g U-235 was determined to have been put in bottles and drums from the sealand. Samples taken from the soil below the sealand indicated that contamination did not leak from the sealand into the soil.
Final analysis of the contents of the sealand container by the licensee indicates that less than 700 g U-235 total was actually present in the sealand.
The licensee's re-analysis of the event (NCS-2025-016, dated April 16, 2025) included bounding assessments of the potential mass and flooding upsets resulting from this event.
The inspectors reviewed this analysis, including its demonstration of double contingency and the modeling of upset conditions, especially modeling and bounding assumptions related to reflection and moderation due to flooding, and the licensee's determination of reportability for this condition under 10 CFR 70 Appendix A.
No violations were identified, therefore, URI 07000027/2025001-01, "Sealand Accumulation,"
is closed.
Corrective Action Reference(s): The licensee's activities to clean up legacy waste were conducted as part of an extent of condition from an event involving legacy waste at another site (CA202100539). The licensee entered this accumulation event into their CAP as CA202500336.
EXIT MEETINGS AND DEBRIEFS The inspectors verified no proprietary information was retained or documented in this report.
On August 7, 2025, the inspectors presented the nuclear criticality safety inspection results to David Faidley and other members of the licensee staff.
10 DOCUMENTS REVIEWED Inspection Procedure Type Designation Description or Title Revision or Date 88015 Calibration Records RP-07-79, Form 1 In-Line Monitor Calibration Record, for RP3002 07/25/2025 88015 Engineering Evaluations NCS-2015-103 NCS Safety Analysis Supporting SER 15-030 Phase 01 thru Phase 03 - S1B Qualification Fillers Fabrication, Pack Assembly and Element Fabrication 10/28/2015 88015 Engineering Evaluations NCS-2018-047 NCS Safety Analysis Supporting SER 17-063 Phase 01 Higher Loaded VTC Packs, Elements, and Met. Lab Samples 05/29/2018 88015 Engineering Evaluations NCS-2025-016 NCS Safety Concern for Legacy Equipment at Waste Treatment - CA202500336 04/16/2025 88015 Engineering Evaluations NCS-2025-042 NCS Safety Concern for Pickle Tank Crane Sensor Failure per CA-202500572 05/05/2025 88015 Engineering Evaluations NCS-2025-047 Nuclear Criticality Safety Concern for In-Line Monitor per CA202500585 06/10/2025 88015 Engineering Evaluations NCS-2025-066 NCS Safety Concern for CA202500941 - Filter Housing Rupture 07/28/2025 88015 Engineering Evaluations NCS-PA 00003 Nuclear Criticality Safety Evaluation of Dry Horizontal Operations with Discrete NR Fuel Elements Rev. 1 88015 Engineering Evaluations PSI-RP-24-007 Criticality Accident Alarm System Analyses: NOG-L Retention Tank Area Rev. 0 88015 Engineering Evaluations RPTWR Number:
2025-001 Summary of CIDAS 2024 Alarms, Failures, Upgrades and Non-routine Maintenance 01/14/2025 88015 Engineering Evaluations Safety Analysis Report 15.21 Low Level Radioactive Waste Processes Waste Operations 03/27/2025 88015 Engineering Evaluations Safety Analysis Report 15.27 NR Fuel Element Fabrication Process 03/27/2025 88015 Miscellaneous Status of CAAS Upgrades 07/30/2025 88015 Miscellaneous 2024 Annual Emergency Management Organization Training Position Specific Training, Nuclear Criticality Safety Coordinator 07/11/2024
11 Inspection Procedure Type Designation Description or Title Revision or Date 88015 Miscellaneous EP-321,
Rev. 07 Retention Tanks Inspection Log January and February 2025 88015 Miscellaneous HS-2024-117 2024 Plant Evacuation Drill Results 10/07/2024 88015 Miscellaneous RP-07-79, Form 4 In-Line Monitor Weekly Reference Check 08/04/2025 88015 Procedures NCS Posting 15-29-001 350-gram Operations Laboratory Area Rev. 2 88015 Procedures NCS-10 Use of Hot Waste Drains Rev. 06 88015 Procedures NCSE-02 NCS Process Analysis Writer's Guide Rev. 2 88015 Procedures NCSE-03 Nuclear Criticality Safety Audits and Inspections Rev. 31 88015 Procedures OP-1003449 Control of Fuel Residue in Met Lab Preparation Rooms Rev. 8 88015 Procedures OP-1004074 Uranium Accountability and Waste Handling for the Chemistry Laboratory Rev. 7 88015 Procedures OP-1004605 Operation of the Chemistry Lab Waste Dilution Column and In-line Monitor Rev. 9 88015 Self-Assessments Nuclear Criticality Safety Inspection Forms 03/18/2025, 04/09/2025, 05/06/2025, 05/07/2025, 05/13/2025, 05/22/2025, 06/03/2025, 06/17/2025, 06/26/2025, 07/22/25, and 07/28/25 88015 Self-Assessments NCS-2025-035 Audits, Inspections and Observations Summary - 1st Quarter 2025 04/14/2025 88015 Self-Assessments NCS-2025-065 Audits, Inspections and Observations Summary - 2nd Quarter 2025 07/10/2025 88015 Work Orders No. 20393287 SC INSP EVAP STEAM HEAT EX TEST 6M URPSM 08/07/2025 88135.02 Corrective Action Documents CA202501026 Fire - UIR 07/26/2025
12 Inspection Procedure Type Designation Description or Title Revision or Date 88135.02 Corrective Action Documents CA202501079 NCS - UIR 08/04/2025 88135.02 Corrective Action Documents CA202501163 Security Event - NRC 08/25/2025 88135.02 Corrective Action Documents CA202501172 Filler Fabrication 08/26/2025 88135.02 Corrective Action Documents CA202501256 UIR - Fire 09/03/2025 88135.02 Corrective Action Documents CA202501281 UIR - Fire 09/04/2025 88135.02 Corrective Action Documents CA202501285 Handling found on storage 09/04/2025 88135.02 Corrective Action Documents CA202501374 RP - UIR 09/23/2025 88135.02 Corrective Action Documents CA202501387 NCS - UIR 09/25/2025 88135.02 Corrective Action Documents Resulting from Inspection CA202501040 Maintenance non-product 07/29/2025 88135.02 Corrective Action Documents Resulting from Inspection CA202501314 Other 09/09/2025 88135.02 Radiation Work Permits (RWPs)
RWP 2025-0048 Demolition of old cyclone enclosure Rev.00 88135.04 Corrective Action Documents 202501145 Inspection 08/21/2025 88135.04 Corrective Action Documents CA202500249 Physical Environment 02/20/2025 88135.04 Corrective Action Documents Resulting from Inspection CA202400439 Physical Environment 03/18/2024
13 Inspection Procedure Type Designation Description or Title Revision or Date 88135.05 Fire Plans section 12a Bay 17 03/07/2017 88135.05 Procedures EPR-02-05 NCS EOC Guidance 01/27/2025 88135.19 Procedures E61-691 Checklist of UPRR maintenance work order assessment Rev. 03 88135.19 Procedures N-307 Lockout / Tagout permit Rev. 3 88135.19 Work Orders 20393986 Complexing Column replacements 07/31/2025 88135.19 Work Orders WO20393936 Replacement of primary scrub column feed pump 07/25/2025 88135.22 Procedures E61-056 vessel calibration/volume check log Rev. 08 88135.22 Procedures E61-672 Endress+Hauser flowmeter calibration form Rev. 07 88135.22 Procedures NCSE - 03 nuclear criticality safety audits and inspections Rev. 31 88135.22 Procedures NCSE-03-01 nuclear criticality safety quarterly audit checklist Rev. 08 88135.22 Procedures NCSE-03-03 nuclear criticality safety inspection form Rev. 05 88135.22 Procedures OP-1013117 operating procedure for volume calibration for MC&A purposes Rev. 6 88135.22 Procedures QWI 05.1.26 nuclear criticality safety postings Rev. 13