ML19177A397
| ML19177A397 | |
| Person / Time | |
|---|---|
| Issue date: | 06/21/2019 |
| From: | Brannen Adkins NRC/RGN-II/DFFI |
| To: | Timothy T AREVA |
| Brannen Adkins, RII/DFFI | |
| References | |
| Download: ML19177A397 (5) | |
Text
- Document Request - Notification of NRC Inspection
Subject:
Wednesday, June 26, 2019 5:25:00 PM Date: image001.png Attachments:
From: Adkins, Brannen Sent: Friday, June 21, 2019 1:52 PM To: TATE Timothy (AREVA) (Timothy.Tate@areva.com) <Timothy.Tate@areva.com>
Cc: MANNING Calvin (AREVA) <Calvin.Manning@areva.com>; Edwards, Denise
<Denise.Anderson@nrc.gov>; Stamm, Eric <Eric.Stamm@nrc.gov>; Glenn, Patricia
<Patricia.Glenn@nrc.gov>; Goff, Gregory <Gregory.Goff@nrc.gov>; Gibson, Richard
<Richard.Gibson@nrc.gov>
Subject:
Document Request - Notification of NRC Inspection
Dear Mr. Tate,
The purpose of this email is to inform you that the NRC will be onsite the week of August 5th for an inspection that covers plant modifications (triennial), nuclear criticality safety, and maintenance and surveillance and to formally request documents to support the inspection.
The inspection team will consist of myself (team lead), Denise Anderson, Eric Stamm, Patricia Glenn, and Gregg Goff. The inspection procedures (IPs) and team assignments are as follows:
- 1. Plant Modifications (Triennial) - IP 88072 (Adkins, Stamm, Anderson)
- 3. Maintenance & Surveillance (M&S) - IP 88025 (Goff)
As you are probably aware, the NRC developed a new, triennial, plant modifications inspection procedure as a response to the Westinghouse scrubber accumulation event.
This will be the first time that the NRC has conducted this inspection. The primary focus of this procedure is to perform a historical review of modifications on a specific system to ensure that the safety basis was adequately maintained in lieu of a random review of modifications from the previous calendar year. The team has preliminarily selected the Dry Conversion Facility (DCF) to perform this historical review of facility changes. Earlier this year you provided the NRC a list of changes to the conversion area that covered the years 2008 to 2018. In addition to this list, we are requesting you to provide a similar list specific to the DCF that covers the entire time period that the DCF has been in operation up until 2008. This will help us develop a final list of modifications to review during the inspection.
If possible, please provide this list by July 12th. Please contact me as soon as possible if you have any concerns or questions regarding this specific request.
The NRC will also be conducting a review of the new SURF facility as part of the PMT and NCS modules. Based on our earlier discussions, it is my understanding that the SURF will be construction complete and undergoing system testing/commissioning at the time of the inspection. Given this information, we are planning on inspecting the SURF from a mods/NCS perspective; however, we may elect to defer this portion of the inspection to the October inspection depending on your progress/status after arriving onsite. As a general principle, we do not typically inspect items that are DRAFT or incomplete. Any additional
information you or your team could provide over the next month on the status of the SURF would be appreciated so that we can better plan for our inspection.
The specific document request for the inspection is included as an attachment to this inspection. Please provide these documents (compact disc or hardcopies) by July 19th to provide adequate time for inspectors to review the documents prior to the inspection.
We are currently planning on a Monday entrance and a Friday exit at 1500. The team felt that a Friday exit was more appropriate given the large inspection scope and unknowns associated with performance of a new inspection procedure.
Starting today, I will be out of the office on leave through July 12th, but will be checking my email on a very infrequent basis. Please feel free to contact me anytime during this time if you have questions or concerns. Phone calls to my work number are also find during this time as my work number is forwarded to my personal cell number. If I dont answer please leave a message and I will return your call.
We are looking forward to the inspection. Thanks in advance for all of your support.
Best Regards, Brannen Adkins Senior Fuel Facility Inspector US Nuclear Regulatory Commission Region II 245 Peachtree Center Ave. NE, Suite 1200 Atlanta, GA 30303
( 404-997-4620
- Brannen.Adkins@nrc.gov
NUCLEAR CRITICALITY SAFETY MAINTENANCE & SURVEILLANCE PLANT MODIFICATIONS TRIENNIAL DOCUMENT REQUEST SITE/LICENSEE: FRAMATOME Richland Facility PRE-INSPECTION VISIT: None INSPECTION DATES: August 5 - 9, 2019 NRC INSPECTORS: Lead Brannen Adkins, Brannen.Adkins@nrc.gov Denise Anderson, Denise.Anderson@nrc.gov Eric Stamm, Noel Eric.Stamm@nrc.gov Gregory (Gregg) Goff, Gregory.Goff@nrc.gov Patricia Glenn, Patricia.Glenn@nrc.gov ACCOMPANYING PERSONNEL None IDENTIFIED LICENSEE CONTACTS:
Licensing Specialist: Timothy (Tim) Tate Note: This is a broad list of the documents the NRC inspectors will be interested in obtaining and reviewing prior to the on-site inspection visit. The current version of these documents is expected unless specified otherwise. Information in the document lists should contain enough information to be easily understood by someone who has knowledge of the subject. The lead inspector may answer questions regarding questions on specific information needs with licensee staff and may request additional documents.
Inspection Procedure 88015 - Nuclear Criticality Safety (P. Glenn)
- 1. Information to be Provided On-site Following Entrance Meeting
- a. List of NCS-related condition reports since the last NCS inspection
- b. Recently revised NCS program procedures (since last inspection)
- c. List of NCSEs associated with the DCF. If necessary, samples for onsite review will be selected from this list.
- d. NCSE for the new SURF facility
- 2. Information requested for onsite review
- b. Validation report (if revised since the last inspection)
- c. Emergency procedures associated with criticality event response (e.g. evacuation)
- d. CAAS test records (past 18 months)
- e. NCS audits, independent audits, self-assessments, or QA surveillances performed since the last NCS inspection (that apply to NCS)
- f. NCS-related condition reports since the last NCS inspection Inspection Procedure 88025 - Maintenance & Surveillance (G. Goff)
- 1. Information Requested for In-Office Preparation
- a. Maintenance & Surveillance (M&S) activities performed from August 2018 till present, especially those that occurred during the last outage. Please include a brief description of the activity, if practical. This list can be reduced to only the M&S activities related to safety-significant tasks such as those involving IROFS or safety-related non-IROFS. The inspector will select the work packages of interest from this list and notify you.
- b. List of any M&S activities scheduled to take place during the week of the inspection (August 5-9, 2019).
- c. Work control procedures related to maintenance activities (i.e., planning, scheduling, and implementation). These procedures may also address work orders. I know Phil Lee has these documents. The actual procedure can also be the work order in certain situations.
- d. Surveillance and calibration testing (i.e., post maintenance testing) procedures. Again, Phil Lee likely has these. If there are any actual procedures (MCP, SOP, etc.) please provide them, too.
- e. Procedures and records relating to the control and use of measurement & testing equipment (M&TE) for equipment used to perform calibrations/surveillances.
- f. Organizational chart of the M&S department.
- g. A list of corrective action program entries related to M&S activities in calendar year 2019 (can go back as far as August 2018). Please include a brief description of the problem, if practical.
- 2. Information Requested for onsite review
- a. Records of surveillance and calibration testing activities for Active-Engineered IROFS and safety-related non-IROFS performed from August 2018 to present.
- b. Audits and/or assessments of the Maintenance & Surveillance program in 2018 or 2019, or the latest available.
Inspection Procedure 88072 - Plant Modifications Triennial (B. Adkins, D. Anderson, E.
Stamm)
- 1. Information Requested for In-Office Preparation
- a. Engineering/CM organization chart
- b. List of system engineers and assigned systems for the DCF
- c. Plant modifications (PM) program-related procedures including post-mod testing
- d. The focus of the inspection will be on mods completed in the Dry Conversion Facility between startup until 2018. Please provide a list of mods in the DCF that covers the time from facility startup until 2008. (NOTE: we have the list of mods in the conversion area that covers 2008 to 2018 which includes DCF). NOTE:
Please provide this list ASAP so that we can provide you with the specific mods that will be requested for on-site review. IF this list too extensive, you may limit the list to significant modifications including ones that impacted the ISA or safety bases.
- e. List of current outstanding design issues (including open/deferred or canceled engineering action items), temporary modifications, and operator workarounds for the DCF
- f. List of active corrective maintenance work requests/orders for the DCF
- 2. Information Requested for On-site Review
- g. Provide the following documents for the DCF:
- a. Piping and Instrument diagrams
- b. Electrical single line diagrams
- c. Process Hazards Analysis (PHA)
- d. System descriptions
- e. Operations procedures
- f. ISA Summary (various revisions upon request)
- h. List of condition reports for last 12 months (or since the last inspection) pertaining to PM/engineering program activities
- i. List of open condition reports associated with the DCF Miscellaneous Requests
- 1. Request for a tour of the DCF and SURF following the entrance meeting
- 2. Meeting with the DCF engineer and appropriate personnel to discuss major changes (physical and ISA related) to the DCF since commissioning (including ECR numbers) -
Tue am
- 3. Provide NRC access to the Framatome condition report system
- 4. Provide access to requested ECRs (paper/files or electronic system as applicable)