ML19025A017
| ML19025A017 | |
| Person / Time | |
|---|---|
| Site: | Framatome ANP Richland |
| Issue date: | 01/25/2019 |
| From: | Eric Michel NRC/RGN-II/DFFI/FFB2 |
| To: | Land R Framatome |
| References | |
| IR 2018005 | |
| Download: ML19025A017 (12) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 January 25, 2019 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 70-1257/2018-005
Dear Dr. Land:
This letter refers to inspections conducted from October 1 - December 31, 2018, at the Framatome Inc., facility in Richland, Washington. The purpose of these inspections was to perform routine reviews of the performance areas of Safety Operations and Facility Support.
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 November 1, 2018.
Based on the results of these inspections, the Nuclear Regulatory Commission (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.
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:
(See page 2)
R. Land 2
Enclosure:
NRC Inspection Report 70-1257/2018-005 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
ML19025A017 SUNSI REVIEW COMPLETE FORM 665 ATTACHED OFFICE RII:DFFI RII:DFFI RII:DFFI RII:DFFI RII:DFFI RII:DFFI NMSS:FCSE SIGNATURE Electronically Electronically Electronically Electronically Electronically Electronically NAME MRuffin KKirchbaum TVukovinsky KWomack NPitoniak GGoff DATE 01/ /2019 01/ /2019 01/ /2019 01/ /2019 01/ /2019 01/ /2019 01/ /2019 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.: 70-1257/2018-005 Licensee: Framatome Inc.
Facility: Richland Facility Location: Richland, Washington 99354 Dates: October 1 - December 31, 2018 Inspectors: K. Kirchbaum, Operator Licensing (A.2)
N. Pitoniak, Senior Fuel Facility Project Inspector (A.1)
M. Ruffin, Fuel Facility Project Inspector (A.2)
T. Vukovinsky, Senior Fuel Facility Project Inspector (A.2)
K. Womack, Fuel Facility Inspector (B.1)
Approved by: E. Michel, Chief Projects Branch 2 Division of Fuel Facility Inspection Enclosure
EXECUTIVE
SUMMARY
FRAMATOME INC.
NRC Integrated Inspection Report 70-1257/2018-005 October 1 through December 31, 2018 Inspections were conducted by regional inspectors during normal shifts in the performance 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 Operational Safety Program. (Paragraph A.1)
- No violations of more than minor significance were identified related to the Fire Protection Program (Triennial). (Paragraph A.2)
Facility Support
- No violations of more than minor significance were identified related to the Emergency Preparedness Program. (Paragraph B.1)
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. Operational Safety (Inspection Procedure 88020)
- a. Inspection Scope The inspectors interviewed licensee engineers, operators, and managers, and reviewed records associated with systems 140 (Engineering Laboratory Operations (ELO) Pellet Dissolver), 180 (Gadolinia Scrap Uranium Recovery), and 810 (Dry Conversion Facility (DCF) Vaporization), focusing specifically on the DCF autoclaves to verify compliance with E10-08-011, License Application Chapter 11. The inspectors reviewed a select sample of the items relied on for safety (IROFS) associated with these systems identified in the Integrated Safety Analysis (ISA).
The inspectors performed field walk-downs of the ELO and DCF to verify the field configurations were maintained in accordance with the configuration control requirements of the License Application Chapter 11.1.2. The inspectors conducted interviews, document reviews, and field observations to verify that the licensee conducted preventative maintenance and surveillance as required by the ISA Summary for systems 140, 180, and 810. Specifically, the inspectors reviewed documentation associated with IROFS 813, 816, 902, 903, 905, 906, 924, and 926.
The inspectors observed UF6 cylinder movements in the areas of line 1 autoclaves V1-101 and V1-102 to verify compliance with E04-NCSA-810, Dry Conversion Vaporization System, Version 12. The inspectors interviewed engineering and maintenance personnel regarding autoclave vessel inspections to verify compliance with IROFS 905 autoclave vessel containment requirements in accordance with the ISA and S810P001, Pressure Vessel Inspection requirements.
The inspectors reviewed training records regarding initial and continuing training programs to verify compliance with the training requirements of the License Application Chapter 11.3.2. The inspectors also reviewed operations training records for 13 qualified operators to verify compliance with SOP-41068, Training and Qualifications, Section 4.0, Version 3.0 regarding continuing training requirements.
The inspectors reviewed procedures and records (see attached list of documents) to verify that required actions, as identified in the ISA Summary, had been accurately transcribed into written procedures as required by the License Application Chapter 11.4.
2 The inspectors reviewed the licensees corrective action program entries for the past 12 months affecting safety controls to verify that deviations from procedures and unforeseen process changes affecting nuclear criticality, chemical, radiological, or fire safety were documented and investigated per the License Application Chapter 11.6.
b. Conclusion
No violations of more than minor significance were identified.
- 2. Fire Protection - Triennial (Inspection Procedure 88054)
- a. Inspection Scope The inspection effort focused on the DCF, UO2 building, the Specialty Fuel (SF) building, ELO, warehouses, and the maintenance building. The inspectors reviewed the Fire Hazards Analysis (FHAs) for each of these facilities to determine compliance with Chapter 7 - Fire Safety of the License Application. The inspectors performed walk downs of passive fire protection features, primarily designated firewalls, to verify the material condition and configuration as required in the Pre-Emergency Plans. The inspectors also evaluated the preventative maintenance records and procedures for the fire dampers in the process areas to verify compliance with Chapter 11 - Management Measures of the License Application.
The inspectors reviewed the licensees combustible and flammable material control and ignition source programs. The inspectors noted that the combustible and flammable material control program included IROFS 4502, which limits the amount and proximity of combustible and flammable materials, and IROFS 4503, which provides an independent procedural verification to verify compliance with the MCP-30031, Flammable and Combustible Liquids/Solids Storage and Handling, Version 12.0. The inspectors selected a sample of designated loading zones in DCF and the UO2 process areas to verify that they were below the allowable combustible material storage amounts designated in drawing CSA-607.590. The inspectors reviewed the hot work permit program to verify that the licensee established measures to control ignition sources throughout the facility as required by MCP-30039, Hot Work Procedure, Version 10.0.
The inspectors reviewed postings for water fire-fighting restrictions in effect for the applicable process areas to verify they were in compliance with fire/criticality safety requirements of E04-NCSS-G06, Fire Prevention and Firefighting, Version 28.0. The inspectors noted no environmental issues that could be caused by the use of water-based suppression systems at the plant.
The inspectors performed walk downs to verify that specific fire protection equipment such as extinguishers, heat detectors, smoke detectors, pull boxes, strobe lights, speakers, and emergency lighting were in the correct locations as indicated on approved plant drawings.
The inspectors reviewed the licensees program regarding fire response capability. The inspectors reviewed the training for personnel regarding administrative IROFS for the process buildings (E04-NCSS-G06, Fire Prevention and Firefighting,g Version 28.0).
The inspectors also spoke with several operators on the process floor regarding their expected response to a fire, and noted their response was in accordance with the
3 procedures (i.e., evacuate if a fire is noted). The inspectors also reviewed the licensees annual general employee safety training to ensure that it contained the general awareness training with respect to fire safety as stated in the License Application.
The inspectors reviewed recent corrective actions, audits, and several preventive maintenance records to determine if the licensee was adequately identifying, assessing, and resolving issues. The inspectors also reviewed the Fire Hazard Management Inspection Report, Richland Plant, June 21-24, 2016, and the corrective actions it generated.
b. Conclusion
No violations of more than minor significance were identified.
B. Facility Support
- a. Inspection Scope The inspectors reviewed the Emergency Preparedness (EP) program to verify compliance with Chapter 8 - Emergency Management of the License Application. The inspectors interviewed staff and reviewed records to verify that no changes had been made to the Emergency Plan or within the facility by the EP organization that required prior NRC approval. The inspectors reviewed Emergency Plan written agreements with offsite agencies, implementing procedures that changed since the last EP inspection, and interviewed off-site agency staff members to determine that changes were in compliance with the Emergency Plan, did not diminish safety, and were communicated appropriately to off-site groups. The inspectors reviewed on-site locations required to have copies of the Emergency Plan and implementing procedures to verify whether the most current copies were readily available to members of the Plant Emergency Response Team (PERT).
The inspectors reviewed training records for various members of the PERT, as well as the Plant Emergency Response Management Team (PERMT) in order to verify that training requirements were satisfied as required by the Emergency Plan. The inspectors observed first aid training conducted by Kadlec Regional Medical Center staff to PERT members. The inspectors reviewed training given to PERMT members to verify that it covered expected emergency scenarios. The inspectors also reviewed training given to offsite support agencies to verify that training included firefighting instructions and contamination control as appropriate for each agency.
The inspectors reviewed the Memorandum of Agreement (MOA) with off-site agencies to verify that the organizations required by the Emergency Plan had up-to-date agreements, a copy of the most current Emergency Plan, and copies of the most recent implementing procedures. The inspectors interviewed off-site organization representatives from Kadlec Regional Medical Center, Richland Fire Department, and Richland Police Department to verify that they maintained an adequate understanding of written agreements and that the licensee invited each organization for tours, training, and drill participation as required by the Emergency Plan
4 The inspectors observed the storage of emergency equipment in multiple staging areas to verify that required equipment listed in EP procedures was available for use. The inspectors observed the calibration of radiation protection equipment, hydrostatic testing dates of SCBA cylinders, and inspection dates on respirators and other emergency response equipment. The inspectors observed the Emergency Operation Center and the adjacent storage annex to verify that the facilities contained operable communications and other equipment required by EP procedures and the Emergency Plan.
The inspectors reviewed records of the operational readiness of on-site communication radios to verify testing was performed in accordance with E08-01-1.0, Emergency Plan, Version 13.0. The inspectors also reviewed the Emergency Plan to determine whether the licensee maintained its certification of compliance with the Emergency Planning and Community Right-To-Know Act of 1986.
The inspectors reviewed the latest licensee conducted internal audit of the EP program to verify that audits were conducted in the area of EP as required by the License Application Chapter 11.5. The inspectors also reviewed the audits to verify that findings in the area of EP were being identified, captured, and corrected in a timely manner. The inspectors reviewed the scenario of the most recent biannual table top drill to verify it used a credible, challenging scenario and that corrective actions following drill critiques were being captured and evaluated.
b. Conclusion
No violations of more than minor significance were identified.
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 November 1, 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 J. Bourgeois Engineering Tech Support and Maintenance J. Campbell Training Specialist J. Diest Emergency Preparedness Coordinator R. Duncan Battalion Chief, Richland Fire Department D. Harris Principal Mechanical Engineer T. Knox ELO Supervisor J. Kreitzberg Criticality Safety Engineer P. Lee SAP Administrator/Coordinator for Maintenance B. Mooney Design Engineer Specialist S. Nunez Security & Emergency Preparedness Manager K. Olsen Plant Engineer T. Tate Manager, Environmental, Health, Safety, & Licensing J. Zito Engineering
- 2. LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED None
- 3. INSPECTION PROCEDURES USED 88020 Operational Safety 88050 Emergency Preparedness 88054 Fire Protection (Triennial)
- 4. DOCUMENTS REVIEWED Records:
Audit 18.72, U.S. Fuel, EHS&L Richland, WA, August 27-30, 2018 C185I002, Analyzer Uranium, IROFS Analyzer Gamma Energy, dated January 30, 2018 C205I001-0001, Scale MOP Water A 1YR IN, dated June 13, 2018 C205I001-0002, Scale MOP Water B 1YR IN, dated June 13, 2018 CG06P012, Fire Hydrant Flow Test 12MO, dated June 25, 2018 CG06P013, Fire Door 12 MO MW, dated August 17, 2018 CG06P014, Fire Protection Wall Inspection 6 MO SA, dated October 24, 2017 CG06P014, Fire Protection Wall Inspection 6 MO SA, dated April 4, 2018 CG06P015, Fire Extinguishers 1 MO AB, dated August 28, 2018 CG06P016, Fire Damper 1 Yr MW, dated July 30, 2018 CG06P017, Door Fire (#63) SF174 12 MO RE, dated August 1, 2018 CG06P018, Fire Damper 1 Yr MW, dated July 17, 2018 CG06P019, Fire Sprinklers 3 MO PS. dated February 6, 2018 CG06P019, Fire Sprinklers 3 MO PS. dated May 9, 2018 CG06P019, Fire Sprinklers 3 MO PS. dated September 12, 2018 Attachment
2 Criticality System retraining: System 820 - Dry Conversion Powder Production, dated January 17, 2018 Criticality System retraining: System 830 - Dry Conversion Powder Production, dated January 17, 2018 Engineering Change Notice (ECN)-8843 Engineering Change Notice (ECN)-8849 IROFS 4502 - ISA Data Entry IROFS 4503 - ISA Data Entry PM 000030, Emergency Lights 1 YR AB, dated September 20, 2018 PM 000031, Emergency Lights 1 YR AB, dated May 22, 2018 PM 000032, Emergency Lights 1 YR AB, dated January 25, 2018 PM 004337, Emergency Lights Plantwide 1 MO AB, dated October 19, 2018 PM 003884, Emergency Lights 1 MO AB, dated October 18, 2018 PM 004338, Emergency Lights Plantwide 1 MO AB, dated October 11, 2018 PM C810P009-0001, DC Autoclave 6 mo MWHZ Line 1, V1-101, dated April 26, 2018 PM C810P009-0003, DC Autoclave 6 mo MWHZ Line 2, V2-101, dated September 5, 2018 PM C810P009-0005, DC Autoclave 6 mo MWHZ Line 3, V3-101, dated May 3, 2018 Post Drill Critiques & Lessons Learned from April 2017 Exercise Preliminary US Fuel Internal Audit Report, 10/05-27/2017 (Annual EP Audit Report)
PM CP10P009 - DC Autoclave 6 mo MWHZ, Revision (Rev.) 0 PM S810P001 - Pressure vessel Inspection 1mo Re, Rev. 4 US Fuel Internal Audit Report, October 10-27, 2016 (Annual EP Audit Report)
Procedures:
ADM-00006, Administrative Procedure for Documentum DCM Documents, Version 29.0 ADM-00008, Control of Operator Aids in Richland Operations, Version 8.0 E04-05-01, Nuclear Criticality Safety Standards, Version 16.0 E04-NCSA-810, Dry Conversion Vaporization System, Version 12.0 E04-NCSS-G06, Criticality Safety - NCSS, Fire Prevention and Firefighting, Version 28.0 E08-01-1.0, Emergency Plan, Version 13.0 E08-04-2.12, Emergency Preparedness - Part IV - MOUs, Version 4.0 E10-08-002, Organization and Administration, Version 5.1 E15-03-002, Integrated Safety Analysis Program Standards, Version 9.0 E19-02-006, Management of Environmental, Health, and Safety Records, Version 10.0 MCP-30029, Housekeeping, Version 4.3 MCP-30031, Flammable and Combustible Liquids/Solids Storage & Handling, Version 12.0 MCP-30039, Hot Work Procedure, Version 10.0 MCP-30040, Fire Protection Program, Version 9.0 MCP-30324, Richland procedure Writers Guide, Version 14.0 MCP-30325, Instrument Repetitive Maintenance, Version 14.0 MCP-30379, Construction or Modification Change Control, Version 13.2 MCP-30383, Preventive Maintenance, Version 5.2 SOP-40486, General Standard Operating Procedure, Version 35.0 SOP-40789, Work Order Instructions, Version 17.0 SOP-40791, Maintenance Work Permit (MWP) and Pre-job Briefing (PJB), Version 16.0 SOP-40839, Instrument Repetitive Maintenance, Version 12.1 SOP-40841, Preventive Maintenance, Version 9.2
3 SOP-40857, Maintenance Hot Work Permit Procedure, Version 9.0 SOP-40920, Items Relied on for Safety (IROFS) and Equipment Essential to safety, Version 7.0 SOP-41044, Designated Hot Work Area Requirements Procedure, Version 6.0 SOP-41068, Training and Qualification, Version 3.0 1703-76, Issue Investigation and Causal Analysis Procedure, Revision 23 Condition Reports Written as a Result of the Inspection:
CR 2018-9724, CR 2018-9733, CR 2018-9742 Condition Reports Reviewed:
2017-6987, 2017-7175, 2018-0177, 2018-0305, 2018-0643, 2018-0744, 2018-0842, 2018-0859, 2018-0943, 2018-0948, 2018-0950, 2018-0977, 2018-1335, 2018-1544, 2018-1811, 2018-2053, 2018-2175, 2018-2453, 2018-2598, 2018-2662, 2018-2751, 2018-3249, 2018-3343, 2018-3652, 2018-3755, 2018-3866, 2018-4224, 2018-4364, 2018-4370, 2018-4542, 2018-4707, 2018-4716, 2018-4772, 2018-4778, 2018-4825, 2018-5017, 2018-5031, 2018-5078, 2018-5091, 2018-5139, 2018-5233, 2018-5405, 2018-5457, 2018-5539, 2018-5592, 2018-5593, 2018-5671, 2018-5711, 2018-5852, 2018-6062, 2018-6234, 2018-6474, 2018-6708, 2018-6710, 2018-6740, 2018-6877, 2018-7105, 2018-7115, 2018-7116, 2018-7150, 2018-7154, 2018-7217, 2018-7778, 2018-8380, 2018-8717, 2018-8803, 2018-8809, 2018-9075, 2018-9076, 2018-9185, 2018-9196, 2018-9360, 2018-9395, 2018-9400, 2018-9561 Other Documents:
3rd Quarter Automatic Sprinkler Systems Inspection, Testing, and Maintenance of Wet E08-05, Pre-Emergency Plan E14-02-003, SF Building Fire Hazards Analysis, Version 2.0 E14-02-004, UO2 Building Fire Hazards Analysis, Version 6.0 E24-01-001, Horn Rapids Road Site Fire Hazards Analysis, Version 4.0 E24-01-102, Dry Conversion Facility Fire Hazards Analysis, Version 2.1 EMF-616-411, Sheet 1 International Codes - Adoption by State (October 2015)
Pipe Sprinkler Systems, dated August 14, 2018 System 180 Gadolinia Scrap Uranium Recovery P&ID System 810 Dry Conversion Facility Vaporization P&ID