ML18297A090

Framatome Quarterly IR 2018-004

ML18297A090
Person / Time
Site:	Framatome ANP Richland
Issue date:	10/24/2018
From:	Eric Michel NRC/RGN-II/DFFI/FFB2
To:	Land R Framatome
References
IR 2018004
Download: ML18297A090 (14)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 October 24, 2018 Dr. Ronald J. Land Site Manager Framatome Inc.

2101 Horn Rapids Road Richland, WA 99354-0130

SUBJECT:

FRAMATOME INC. - NUCLEAR REGULATORY COMMISSION INTEGRATED INSPECTION REPORT 70-1257/2018-004

Dear Dr. Land:

This letter refers to inspections conducted from July 1 - September 30, 2018, at the Framatome Inc., facility in Richland, Washington. The purpose of these inspections was to perform routine reviews of the Criticality Safety, Maintenance/Surveillance, and Plant Modifications program areas. The enclosed report presents the results of these inspections. At the conclusion of the inspections, the results were discussed with members of your staff at an exit meeting held on August 9, 2018.

These inspections examined activities conducted under your license as they relate to public health and safety, the common defense and security, and compliance with the Commission's rules and regulations and with the conditions of your license. Within the areas mentioned above, the inspections consisted of selected examinations of procedures and representative records, observations of activities, and interviews with personnel. Based on the results of these inspections, the NRC has determined that no violations of more than minor significance were identified.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice and Procedure," a copy of this letter and its enclosure, will be made available electronically for public inspection in the NRC Public Document Room or from the NRC's Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.

R. Land 2 If you have any questions, please contact Noel Pitoniak of my staff at 404-997-4634.

Sincerely,

/RA/

Eric C. Michel, Chief Projects Branch 2 Division of Fuel Facility Inspection Docket No. 70-1257 License No. SNM-1227

Enclosure:

NRC Inspection Report 70-1257/2018-004 w/Supplemental Information cc:

Calvin D. Manning, Manager Licensing and Compliance Framatome Inc.

2101 Horn Rapids Road Richland, Washington 99354 William L. Doane, Jr., Manager Nuclear Criticality Safety Framatome Inc.

2101 Horn Rapids Road Richland, Washington 99354 Timothy J. Tate, Manager Environmental, Health, Safety & Licensing Framatome Inc.

2101 Horn Rapids Road Richland, Washington 99354 Mike Elsen, Director Office of Radiation Protection Department of Health PO Box 47827 Olympia, Washington 98504-7827 Mike.Elsen@doh.wa.gov Earl Fordham, Deputy Director Office of Radiation Protection Department of Health 309 Bradley Boulevard, Suite 201 Richland, Washington 99352

ML18297A090 SUNSI REVIEW COMPLETE FORM 665 ATTACHED OFFICE RII:DFFI RII:DFFI RII:DFFI RII:DFFI NMSS:FCSE SIGNATURE Electronically Electronically Electronically Electronically Electronically NAME PGlenn NPeterka GGoff NPitoniak KRamsey DATE 10/11/2018 10/04/2018 10/16/2018 10/16/2018 10/04/2018 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO U. S. NUCLEAR REGULATORY COMMISSION REGION II Docket No.: 70-1257 License No.: SNM-1227 Report No.: 70-1257/2018-004 Licensee: Framatome Inc.

Facility: Richland Facility Location: Richland, Washington 99354 Dates: July 1 - September 30, 2018 Inspectors: P. Glenn, Fuel Facility Project Inspector (Paragraph B.1)

G. Goff, Fuel Facility Project Inspector (Paragraph B.2)

N. Peterka, Fuel Facility Project Inspector (Paragraph A.1)

K. Ramsey, Headquarters Project Manager (Paragraph B.2)

Approved by: E. Michel, Chief Projects Branch 2 Division of Fuel Facility Inspection Enclosure

EXECUTIVE

SUMMARY

FRAMATOME INC.

NRC Integrated Inspection Report 70-1257/2018-004 July 1 through September 30, 2018 Inspections were conducted by regional inspectors during normal shifts in the areas of safety operations and facility support. The inspectors performed a selective examination of licensee activities that were accomplished by direct observation of safety-significant activities and equipment, tours of the facility, interviews and discussions with licensee personnel, and a review of facility records.

Safety Operations

• No violations of more than minor significance were identified related to the Nuclear Criticality Safety Program. (Paragraph A.1)

Facility Support

• No violations of more than minor significance were identified related to the Maintenance and Surveillance Program. (Paragraph B.1)

• No violations of more than minor significance were identified related to the Plant Modification/Configuration Management Program. (Paragraph B.2)

Supplemental Information Key Points of Contact List of Items Opened, Closed, and Discussed Inspection Procedures Used Documents Reviewed

REPORT DETAILS Summary of Plant Status The Framatome facility converts uranium hexafluoride (UF6) into uranium dioxide (UO2) for the fabrication of low-enriched fuel assemblies used in commercial light water reactors. During the inspection period, normal production activities were ongoing.

A. Safety Operations

1. Nuclear Criticality Safety (Inspection Procedure 88015)

a. Inspection Scope The inspectors reviewed the licensees criticality safety program to verify compliance with Chapter 5 (Nuclear Criticality Safety) and Chapter 11 (Management Measures) of the license application (LA); select chapters in the Integrated Safety Analysis Summary (ISA Summary); and 10 Code of Federal Regulation (CFR) 70 requirements. The inspectors reviewed criticality safety documents (see the attachment to this report),

performed walk-downs of processing and storage areas, and conducted interviews with senior managers, supervisors, and engineers to verify that the program was being implemented in accordance with the documents listed above.

Criticality Analysis The inspectors reviewed selected nuclear criticality safety analyses (NCSAs) to determine whether properly reviewed and approved NCSAs were in place prior to conduct of new or changed operations and were of sufficient detail and clarity to permit independent review. The inspectors reviewed the selected NCSAs and associated assumptions and calculations to verify that they were consistent with the commitments in the LA, including consideration of the Double Contingency Principle, assurance of subcriticality under normal and credible abnormal conditions with the use of subcritical margin, technical practices and methodologies, and treatment of nuclear criticality safety (NCS) parameters. The NCSAs were selected based on factors such as whether or not they were new and/or revised, complexity, and operating history. The NCSAs reviewed are listed in Section 4 of the Attachment.

The inspectors reviewed the licensees generation of accident sequences to determine whether the NCSAs systematically identified normal and credible abnormal conditions in accordance with the commitments and methodologies in the LA for the analysis of process upsets. This included the review of accident sequences/upsets that the licensee determined to be not credible to determine whether the bases for incredibility were consistent with the commitments, definitions, and methodologies in the LA, and were documented in sufficient detail to permit an independent assessment of credibility.

Additionally, the inspectors reviewed selected accident sequences designated as not credible to determine whether the bases for incredibility rely on any items which should be identified as formal NCS controls or items relied on for safety (IROFS). This review was conducted in the areas of Bundle Assembly and Storage and the Modular Extraction

/ Recovery Facility (MERF) for the following NCSAs E04-NCSA-785 and E04-NCSA-540.

2 Criticality Implementation The inspectors performed walk-downs for systems 390, 540, and 785 (UO2 Pelleting, MERF, and Bundle Assembly) to determine whether existing plant configuration and operations were covered by, and consistent with, the process description and safety basis in the selected NCSAs listed above. The inspectors reviewed process and system descriptions, specifications, drawings to verify that engineered controls established in the NCSAs were included. The inspectors reviewed operating procedures and postings to verify that selected administrative controls established in the NCSAs were included.

The inspectors interviewed operators and engineers to verify that administrative actions established in the NCSAs were understood and implemented properly.

The inspectors reviewed the ISA summary and supporting ISA documentation to determine whether the controls identified in the ISA were supported by technical basis in the NCSAs.

Criticality Operational Oversight The inspectors reviewed records of NCS audits and accompanied licensee NCS engineers on walk-downs of various areas of the facility and observed the engineers interacting with maintenance and operations staff to determine whether NCS staff routinely inspected fissile material operations to ascertain that criticality requirements were being satisfied. Additionally, the inspectors interviewed NCS engineers and reviewed audit records that had been documented since the last NCS inspection.

Criticality Programmatic Oversight The inspectors reviewed the selected NCSAs listed above to verify that they were performed in accordance with NCS program procedures and received appropriate independent review and approval.

Criticality Corrective Action The inspectors reviewed selected NCS-related condition reports to determine whether anomalous conditions were promptly identified and entered into the Corrective Action Program (CAP), whether they received the appropriate level of investigation consistent with license commitments and procedures, whether proposed corrective actions were sufficiently broad, whether they were prioritized on a schedule commensurate with their significance, and whether they were completed as scheduled and were adequate to prevent recurrence. Additionally, the inspectors reviewed NCS-related CAP entries to assess NRC reportability. The CAP entries reviewed included 2018-4719, 2018-2751, and 2018-4542.

b. Conclusion

No violations of more than minor significance were identified.

3 B. Facility Support

1. Maintenance and Surveillance of Safety Controls (Inspection Procedure 88025)

a. Inspection Scope The inspectors reviewed the licensees maintenance and surveillance program to verify compliance with section 11.3, Maintenance of the LA and licensee procedures.

Specifically, the inspectors performed document reviews (see attachment section 4);

performed system walk-downs; and interviewed managers, supervisors, engineers, and technicians to verify that maintenance and surveillance program activities were conducted as required by procedure. The inspectors observed maintenance and surveillance activities for a sample of IROFS and other safety controls. The evaluations were conducted to verify that sampled safety controls remained available and reliable to perform the safety function when needed as per licensee procedures and requirements.

The inspectors reviewed nine work packages to determine whether the packages were adequately reviewed by the licensee prior to returning the equipment to service (see attachment section 4).

The inspectors observed daily maintenance planning and turnover meetings to verify that provisions were in place to ensure pre-job planning and preparation of work orders.

The inspectors reviewed seven maintenance and surveillance work orders and the associated post maintenance testing records to determine accuracy and whether the functionality of IROFS (or other safety controls) were verified to be operational as per maintenance procedures and ISA accident sequences. In addition, the inspectors assessed the work orders to verify accuracy, that each contained the required level of detail, and that post-maintenance testing and calibrations (as specified by the license requirements and procedures), were performed prior to restoring the equipment to operational status.

The inspectors interviewed a maintenance supervisor regarding the training and qualification program for maintenance personnel performing work on safety-related equipment, including IROFS, to verify compliance with the requirements of the LA section 11.3, Training and Qualifications. The inspectors reviewed a sample of training records of new hires and recently qualified maintenance staff to verify that these individuals were qualified to perform their assigned maintenance activities in accordance with procedures.

The inspectors reviewed the licensees CAP to verify that performance issues relating to the maintenance and surveillance of IROFS and safety controls were entered into the program. The inspectors also reviewed that the CAP to determine that the program evaluated the adequacy of actions taken as required by procedure.

b. Conclusion

No violations of more than minor significance were identified.

4

2. Plant Modifications (Inspection Procedure 88070)

a. Inspection Scope The inspectors reviewed the licensees configuration management program to verify compliance with Chapter 11 (Management Measures) of the LA; select chapters in the ISA Summary; and 10 CFR 70 requirements. The inspectors reviewed configuration management program documents (see the attachment to this report), performed walk-downs of select modifications, and conducted interviews with senior managers, supervisors, and engineers to verify that the program was being implemented in accordance with the aforementioned requirements. The inspectors observed how the licensee evaluated, implemented, and tracked plant modifications which could affect safety as per the applicable procedure (see the attachment).

The inspectors reviewed the licensees configuration management program to verify that the required pre-job planning was addressed in the preparation of plant modification design packages. The inspectors also verified that the configuration management program had provisions to ensure that plant modifications did not degrade the performance capabilities of IROFS or other safety controls that are part of the safety design basis.

The inspectors reviewed a selection of plant modification design packages (see the attachment) since the last plant modification inspection. The inspectors reviewed these packages and interviewed licensee staff to verify that the change packages were prepared, reviewed, and completed by the licensee in accordance with the procedure.

The inspectors also determined that selected engineering change packages included the applicable testing requirements prior to implementation of the plant modification. The inspectors also noted that completed modifications were adequately reviewed prior to implementation. The inspectors also determined that the evaluators responsible for the plant modification packages were qualified.

The inspectors reviewed modification packages to verify that the licensee addressed criteria stipulated in 10 CFR 70.72(c) regarding plant modifications not needing prior NRC approval. The inspectors also reviewed modification packages to verify that the licensee addressed the impacts of modifications to the ISA Summary developed in accordance with 10 CFR 70.61 and 70.62.

The inspectors reviewed audits and assessments of the licensees configuration management program to verify compliance with Chapter 11 of LA. The inspectors also reviewed the licensees CAP to verify that issues identified by these audits/assessments were entered into the CAP and the licensee assigned corrective actions in accordance with procedures.

b. Conclusion

No violations of more than minor significance were identified.

5 C. Exit Meeting The inspection scope and results were presented to members of the licensees staff at various meetings throughout the inspection period and were summarized on August 9, 2018, to R. Land and staff. No dissenting comments were received from the licensee. Proprietary information was discussed but not included in the report.

SUPPLEMENTAL INFORMATION

1. KEY POINTS OF CONTACT Name Title W. Doane Manager; Nuclear Criticality Safety D. Hanson Mechanical Engineer C. Hodge DCF Area Lead L. Hope Technical Training Manager C. Kahambwe Criticality Safety Engineer A. Landon UCAR Technical Support Supervisor R. Lansing SURF Construction Manager P. Lee SAP Administrator/Coordinator for Maintenance J. Mabry DCF Control Room C. Manning Licensing and Compliance Manager J. Marshall Technical Lead for SURF M. Miller Project Engineer B. Nelson Criticality Safety Engineer L. Schinnell Rods, Bundles, and Cages Manager T. Tate Manager Safety, Security, and EP

2. LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED None

3. INSPECTION PROCEDURES USED 88015 Nuclear Criticality Safety 88025 Maintenance and Surveillance of Safety Controls 88070 Plant Modifications

4. DOCUMENTS REVIEWED Records:

Nuclear Criticality Safety E04-07-201802, NCS Audits/Inspection Report - February 2018, Version 1.0 E04-07-201803, NCS Audits/Inspection Report - March 2018, Version 1.0 E04-07-201804, NCS Audits/Inspection Report - April 2018, Version 1.0 E04-NCSA-390, U02 Pellet Grinding and Inspection, Version 19.0 E04-NCSA-540, Bundle Assembly and Storage, Version 13.0 E04-NCSA-545, Product Development Test Facility, Version 3.0 E04-NCSA-785, Modular Extraction/Recovery Facility, Version 6.0 Attachment

2 Maintenance and Surveillance of Safety Controls WO 13345132, dated August 1, 2017 WO 13322981, dated February 5, 2017 WO 13365225, dated February 20, 2018 WO 13317568, dated January 1, 2018 WO13348273, dated September 30, 2017 WO 13358003, dated December 24, 2017 WO 1331778, dated January 1, 2017 WO 13358228, dated December 17, 2017 WO 13348487, dated October 1, 2017 8/6/2018 Maintenance Schedule 4 Personnel Training Record Files (Maintenance Staff)

Plant Modifications Annual Configuration Control Audit Report - 2017, dated November 14, 2017 Configuration Management Triennial Assessment, February 9-15, 2018 ECN 8801 - MERF Rotary Vacuum Drum Filter Installation (version and date not recorded)

ECN 8823, DC Calciner L1 and L2 Breach/Reactor Impactor Upgrades, Version 3.0, dated March 10, 2017 ECN 8826, I3E Drum Stop, Version 4.0, dated April 6, 2017 ECN 8851 - SURF HVAC and Electrical Installation (date not recorded)

ECN 8763 - Install Conduit and Conductors for new criticality alarm system (version and date not recorded)

ECN 8867 - SURF Process Equipment Installation (version and date not recorded)

PM: C335P002, NFI Conveyor Drum Stops, dated October 5, 2016 PM: C355P002, BLEU Room 153 Conveyor Drum Stop 12 Mo OPCH, dated May 21, 2018 PM: C785P003, no title or date recorded Training Qualifications: MCP-30131, Safety/Licensing Evaluation of Facility Changes, Version 10.0 and MCP-30379 (see title below) including all subsections Procedures:

Nuclear Criticality Safety E10-08-005, Version 2.1, SNM-1227- Chapter 5, Nuclear Criticality Safety E04-05-01, Version 16.0, Nuclear Criticality Safety Standards E04-06-002, Version 5.1, Routine Nuclear Criticality Safety Audits Maintenance and Surveillance of Safety Controls MCP-30325, Instrument Repetitive Maintenance (IRM), Version 13.0 MCP-30377, Control and Calibration of Primary Calibration Standards, Version 3.2 MCP-30383, Preventive Maintenance, Version 5.2 SOP-40789, Work Order Instructions, Version 17.0 SOP-40791, Maintenance Work Permit (MWP) & Pre-Job Briefing (PJB), Version 16.0 SOP-40839, Instrument Repetitive Maintenance (IRM), Version 12.0 SOP-40841, Preventive Maintenance, Version 9.1 SOP-40920, Items Relied on For Safety and Equipment Essential Safety, Version 7.0

3 Plant Modifications MCP-30379, Construction or Modification Change Control, Version 13.2, dated January 9, 2018 (including all attachments such as forms and aids)

SOP-40243, Powder Storage (I3A) and Powder Transport Equipment, Version 16.1, dated May 4, 2018 SOP-40943, BLEU Powder Storage (I3E), Version 5.0, dated March 16, 2017 Condition Reports Written as a Result of the Inspection:

Maintenance and Surveillance of Safety Controls 2018-7132 Condition Reports Reviewed:

Nuclear Criticality Safety 2018-2751, 2018-4542, 2018-4716, 2018-4719 Maintenance and Surveillance of Safety Controls 2017-2658, 3200, 4158 Plant Modifications CR2017-83, NCS Infraction 2017-001, Drum stop in I3E did not work and drum fell off the roller. IROFS 213 failed.

CR2018-592, Alpha Air Monitor Removed from Service (SF Building Supply Fan Air Monitor)

CR2018-917, Triennial Self-Assessment of Configuration Management Other Documents:

CSA-617, 079, BLEU Pelleting Powder Storage Area 55 Gallon Drum Fill Station General Arrangement As Built, dated August 15, 2004 E04-NCSA-090, Version 17.0 E04-NCSA-335, Version 23.0 E04-NCSA-355, Version 19.0 E04-NCSA-785, no title, revision, or date recorded E04-NCSS-G01, Version 20.0 E04-NCSS-G81, Version 20.0 Evaluation of Reportability for NCS Infraction 18-009 Evaluation of Reportability for NCS Infraction 18-010 Evaluation of Reportability for NCS Infraction 18-011 Evaluation of Reportability for NCS Infraction 18-013 Evaluation of Reportability for NCS Infraction 18-014 Evaluation of Reportability for NCS Infraction 18-019 EMF-601685, Rev. B - Criticality System Conduit Routing Layout (revision and date not recorded)

EMF-607, 590, AREVA Site General Arrangement, Rev. 29, December 2012 IROFS Failed Report (#2213)

IROFS in Multiple Process Systems IROFS Report (#2213)

ISA - E04-NCSA-820, Version 13.0, Page 67

4 ISA - E15-03-002, Version 4.0, Page 18 ISA Summary License Application Organizational Charts P&ID: CSA-611821, Line 1 Conversion P&ID, Rev.12A, February 2017 P&ID: CSA-611822, Line 2 Conversion P&ID, Rev. 006A, February 2017 P&ID: CSA-616717, Conveyor Barrel & Drum Storage Stop, Rev. 00A, March 2017