ML21298A224

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Framatome-Richland Integrated Inspection Report 07001257/2021003
ML21298A224
Person / Time
Site: Framatome ANP Richland
Issue date: 10/25/2021
From: Eric Michel
NRC/RGN-II/DFFI/FFB2
To: Stephens L
Framatome
References
IR 2021003
Download: ML21298A224 (15)
v • d • e


Text

October 25, 2021 Mr. Lance Stephens Site Manager Framatome Inc.

2101 Horn Rapids Road Richland, WA 99354

SUBJECT:

FRAMATOME-RICHLAND - INTEGRATED INSPECTION REPORT 07001257/2021003

Dear Mr. Stephens:

On September 16, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Framatome-Richland and discussed the results of this inspection with you and other members of 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.

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,

/RA/

Eric C. Michel, Chief Projects Branch 2 Division of Fuel Facility Inspection Docket No. 07001257 License No. SNM-1227

Enclosure:

As stated cc w/ encl: Distribution via LISTSERV

ML21298A224 X Non-Sensitive X Publicly Available X SUNSI Review Sensitive Non-Publicly Available OFFICE RII/DFFI RII/DFFI RI/IDFFI RII/DFFI RII/DFFI NAME T. Vukovinsky G. Goff M. Ruffin B. Adkins E. Michel DATE 10/22/2021 10/22/2021 10/22/2021 10/22/2021 10/25/2021 U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number: 07001257 License Number: SNM-1227 Report Number: 07001257/2021003 Enterprise Identifier: I-2021-003-0116 Licensee: Framatome Inc.

Facility: Framatome-Richland Location: Richland, WA Inspection Dates: September 13, 2021 to September 16, 2021 Inspectors: B. Adkins, Sr. Fuel Facility Projects Inspector G. Goff, Fuel Facilities Inspector M. Ruffin, Fuel Facility Inspector Approved By: Eric C. Michel, Chief Projects Branch 2 Division of Fuel Facility Inspection Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Framatome-Richland, 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 None.

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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.

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 88020 - Operational Safety The inspectors evaluated selected aspects of the licensees Operational Safety program to verify compliance with selected portions of 10 CFR 70, including 70.61 and 70.62, as well as Chapter 3, "Integrated Safety Analysis (ISA) and ISA Summary" and Chapter 11, Management Measures of the facilitys license application, and applicable licensee procedures.

Identification of Safety Controls and Related Programs (IP Section 02.01)

The inspectors selected specific process areas for inspection based on the safety basis information of the facility, the risk/safety significance of the process areas, the description of plant changes submitted to the NRC, and past plant performance documentation. For the process areas of interest, the inspectors selected a sample of accident sequences in nuclear criticality based on the information provided in the integrated safety analysis (ISA) summary and nuclear criticality safety analysis. The process area and accident sequences selected for review are listed below:

  • Process Area is UO2 Powder - System 90 with the following accident sequences:

o Accident Sequence 090-1.2, > 18.43 kg water is transferred to a 45-gallon drum without neutron-absorbing inserts and containing > 40 kg U0x when wet or unconverted ADU is discharged from the calciner o Accident Sequence 090-1.3, > 18.43 kg water is transferred to a 45-gallon drum without neutron-absorbing inserts and containing > 40 kg U0x when significant condensation occurs at the discharge end of the calciner o Accident Sequence 090-4.6, 18.43 kg water or equivalent moderator enters powder production areas of the UO2 powder production system in room 104A and leaks into a 45-gallon drum without neutron-3

absorbing inserts, containing > 40 kg UO2, and located inside the calciner drop enclosure o Accident Sequence 090-5.1, > 15 kg of hydrogenous grease from the calciner bellows leaks into a 45-gallon drum without neutron-absorbing inserts, which contains > 24 kg UOx o Accident Sequence 090-6.3, the drum scale interlock fails to prevent drum overfill and the calciner discharge drop leg fills up with UOx. > 40 kg UOx accumulates in an unfavorable geometry inside the calciner drop enclosure, some of which has fallen from the powder discharge drop leg when the operator raises the fill lid and attempts to remove the drum and the spill is then moderated from a roof or pipe leak o Accident Sequence 090-6.6, a process upset causes discharge from the ADU calciner of a significant quantity of UOx moderated at > 2 wt%

- The diverter valve fails to change position after indication of high moisture, and a 45-gallon drum is not in place and > 40 kg moderated UOx accumulates in an unfavorable geometry inside the calciner drop enclosure o Accident Sequence 090-10.3, > 18.43 kg water is transferred to a 45-gallon drum with neutron-absorbing inserts and containing > 40 kg U0x when significant condensation occurs at the discharge end of the calciner and the drum is transferred from the ADU calciner drop hood to a downstream location without being treated as having moderated contents o Accident Sequence 090-11.1, condensation in the unheated portion of calciner results in at least 18 kg U/ft in any portion of the calciner that is moderated with at least five gallons of water Review of Safety Controls and Related Programs (IP Section 02.02)

The inspectors reviewed information related to enhanced administrative, active-engineered, and passive-engineered safety controls or items relied on for safety (IROFS) for the accident sequences selected above, including the identification of the licensees assumptions and bounding cases as they apply to each of the selected accident sequences, safety controls, or IROFS. This review was performed to verify that the controls or IROFS were available and reliable to perform their intended safety functions and that the design basis assumptions were reflected in the actual conditions in the field. The specific safety controls selected for review are listed below:

  • IROFS 1025.1 (moderation control): nitrogen purge flow (FSA-100) through the RAL prevents the diffusion and condensation of moisture in the unheated portion of the calciner discharge and the interlock will stop the transfer to a 45-gal drum if flow is lost; active engineered control (AEC), criticality safety
  • IROFS 1502 (neutron absorber control): powder drums are equipped with neutron-absorbing inserts, administrative control, criticality safety; passive engineered control (PEC), criticality safety
  • IROFS 2203 (mass control): a scale interlock alerts operations and prevents transfer in NIMS to prevent UOx powder discharge if there is no drum present, 4

and also prevent discharge to a drum that contains no neutron-absorbing insert, enhanced administrative control (EA), criticality safety

  • IROFS 2204 (moderation control): an in-line moisture monitor interlock stops input to the 45-gal drum, AEC, criticality safety
  • IROFS 2206 (moderation control): the hood is equipped with a drum-in-place/lid-down interlock that will stop the rotary valve if a drum is not in place to receive the material, preventing spray from entering the drum and preventing spill of UOx powder and the hood itself also provides protection against water spray, AEC, criticality safety
  • IROFS 2207 (moderation control): the auto greaser is set to deliver no more than 12 lbs. (5.44 kg) per month - if a full 12 lbs. (5.44 kg) reservoir is emptied within a month, NCSS is notified and corrective actions are taken; passive engineered control, criticality safety
  • IROFS 2226 (mass/moderation control): a drum weight monitor is interlocked to stop the rotary valve and prevent drum overfill, AEC, criticality safety Implementation of Safety Controls (IP Section 02.03)

For the selected safety controls listed above, the inspectors reviewed management measures to verify proper implementation in accordance with 10 CFR 70 and Chapter 11 of the license application. This review was performed to verify that selected safety controls or IROFS were present, available, and reliable to perform their safety function and that the design basis assumptions were reflected in the actual conditions in the field. The inspectors conducted the following activities to verify the implementation of selected safety controls:

  • conducted a walk-down of the ADU powder processing area (System 90) including the following IROFS: 1025.1, 2203, 2204, 2206, 2207, and 2226 in the ADU powder processing area
  • reviewed operations procedure SOP-40276, "Calciner Operation - ADU Line 2"
  • observed performance of the following IROFS calibration/maintenance procedure: C355P003, I3E Primary Roof Leak Water Alarms 6 Month Interval
  • observed performance of the following IROFS calibration/maintenance procedure: C355I001, Scale Powder Storage BLEU 3 Month Interval Safety Control Support Programs (IP Section 02.04)

The inspectors assessed additional management measures that support the availability and reliability of the selected safety controls to verify these were implemented in accordance with 10 CFR 70 and Chapter 11 of the license application. Specifically, the inspectors conducted the following:

  • reviewed operator training/qualification records for one ADU System 90 operator
  • reviewed functional testing/calibration work orders for IROFS 2203, 2204, 2206, and 2207 5
  • reviewed the following CAP entries related to failure and degradation of IROFS: 2020-2378; 2020-2465; and 2020-2734
  • reviewed the following non-IROFS related CAP entries associated with regulatory requirements: 2021-443
  • reviewed the December 2020 NCS Audit/Inspection Report covering ADU
  • reviewed the last four Biannual Chemical Safety Audits (latter half of 2019 -

first half of 2021)

FACILITY SUPPORT 88070 - Permanent Plant Modifications The inspectors conducted a review to verify the licensee had established and implemented a configuration management system to evaluate, implement, and track changes to the facility in accordance with the applicable requirements in Title 10 of the U.S. Code of Federal Regulations (10 CFR) Section 70.72 and the License Application, Chapter 11 Section 11.1, "Configuration Management." The inspectors' review also verified the licensee had established management measures for changes to the facility in accordance with 10 CFR 70, Subpart H and the License Application, and that modifications involving new processes met the requirements in 10 CFR 70.64.

Sample Selection (IP Section 02.01)

The inspectors reviewed licensing documents, changes the licensee determined did not require pre-NRC approval under 10 CFR 70.72, and changes that affected the integrated safety analysis summary (ISA) to select changes/modifications to review. To assess whether the licensee conducted evaluations according to their established configuration management system, the inspectors selected the following plant modifications, identified as Engineering Change Notices (ECNs) to review:

  • ECN 8909, Line 6 Press Install
  • ECN 8910, COE-Gd Grinder Line Install
  • ECN 8911, IX Column Demo and Prep
  • ECN 8921, Cylinder Wash Snorkel Improvements Facility Change/Modification Process (IP Section 02.02)

The inspectors reviewed the selected modifications listed above to verify the licensee established a configuration management system in accordance with 10 CFR 70.72 and the conditions of the license. Specifically, the inspectors conducted the inspections activities listed below:

  • reviewed the following procedures o MCP-30131, Safety/Licensing Evaluation of Facility Changes o MCP-30379, Construction or Modification Change Control o MCP-30379 A, Construction or Modification Change Control 6

o MCP-30379 B, Construction or Modification Change Control o MCP-30379 C, Construction or Modification Change Control o MCP-30379 D, Construction or Modification Change Control o MCP-30379 E, Construction or Modification Change Control

  • interviewed licensee staff, performed walk-downs of Line 6, newly installed ion exchange (IX) columns, and the cylinder washing station and reviewed the corresponding configuration management packages
  • reviewed facility documentation associated with the selected changes
  • reviewed the Summary of Facility Changes made during Calendar Year 2020, the ECNs Completed list from January 1, 2021 until August 20, 2021, and a sample of the ISA Summary submitted in January 2021 Management Measures (IP Section 02.03)

For the selected modifications, the inspectors reviewed the management measures established for affected IROFS (or credited safety controls) to verify the management measures ensured the IROFS (or credited safety controls) were available and reliable to perform their intended function as required by 10 CFR 70.61 and the license. Specifically, the inspectors conducted the inspection activities listed below:

  • interviewed project engineers and reviewed change management procedures
  • reviewed affected procedures
  • reviewed test procedures
  • interviewed licensee staff
  • reviewed training records
  • reviewed the following test records:

o C370P002 Hour Meter Readings o C370P003 Pellet Press 500HR o C370P001 Press Line Sludge Measurement o PG 000089 Lifter/Rotator o PM 004775 BLEU Pellet Press o IRM03856 Balance L6 Press o PG000214-0004 CO2 Monitor Alarm o C395P006 Boat Dumper to Hopper o C395I003 Scale L6 Sludge o IRM05201 Scale Grinder Sheet Load o C395I002 Scale Inspection Reject WIT-404 o IRM01142 Transmitter D/P UO o IX Column Demo & Prep Functional Test o C065P007 UF6 Cylinder Wash IROFS Hardware Functional Test

  • reviewed condition reports
  • reviewed the most recent audit of the configuration management system License Application Changes (IP Section 02.04)

For the selected modifications, the inspectors interviewed licensee staff and reviewed applicable sections of the license application to verify the licensee evaluated license application changes and conducted NRC pre-approval screenings in accordance with the license requirements. Specifically, the inspectors conducted the inspection activities listed below:

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  • reviewed the "Safety/Licensing Evaluation of Facility Changes" procedure used to determine whether NRC pre-approval of license application changes is required to verify the licensee correctly evaluated license application changes
  • interviewed licensee staff and reviewed license application change evaluations associated with the selected ECNs New Processes at Existing Facilities (IP Section 02.05)

The licensee had not implemented any new facility processes at the time of the inspection.

Therefore, the inspectors review did not include evaluations of whether the licensee addressed the baseline design criteria and defense-in-depth as stipulated in 10 CFR 70.64.

Records Retention (IP Section 02.06)

The inspectors reviewed a sample of plant documents impacted by the selected modifications to verify the licensee maintained records of facility changes in accordance with the license requirements and 10 CFR 70.72. The sample of documents included:

  • applicable operating procedures
  • system drawings listed in the documents reviewed section of this report
  • ISA Summary Chapters:

o 9A - UO2 Building o 9E - UO2 Building

  • NCSA-960 INSPECTION RESULTS No issues were identified.

EXIT MEETINGS AND DEBRIEFS The inspectors verified no proprietary information was retained or documented in this report.

  • On September 16, 2021, the inspectors presented the integrated inspection results to Lance Stephens and other members of the licensee staff.

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DOCUMENTS REVIEWED Inspection Type Designation Description or Title Revision or Procedure Date 88020 Corrective CR-2020-0840 C328I002 Scale WT-1000 Would Not Power Up DEAD 04/13/2020 Action IROFS 2203. Not a NCS Infraction.

Documents CR-2020-2378 NCS Infraction 20-021 - Two dry SBCs discovered stacked 10/21/2020 in I3A Dry Storage Array - IROFS 2107 Failed CR-2020-2465 NCS Infraction 20-022 SURF valve FV-32901 failed to 10/28/2020 close. IROFS 404.30 Degraded CR-2020-2734 IRM C163I102-0010 found OOT (IROFS 2310). Channel 3 12/04/2020 Gmma monitor fot TK-780 was OOT. The OOT reading would have been 9.84 gU/L.This value is still below the NCSS limit set point of <10 gU/L.

CR-2021-0443 NRC Inspection 2021-001 02/25/2021 Drawings CSA-611090 UF6 ADU PROCESS CALCINING SYSTEM P&ID Revision 14 CSA-611090 UF6 ADU Process Calcining System P&ID Revision 15 Engineering E04-NCSA-090 EHS&L Document Criticality Safety - NCSA UO2 Powder Revision 17 Evaluations Production E15-01-2.9A EHS&L Document, Part 2 - Chapter 9A - UO2 Building Revision 18 Miscellaneous Portfolio Curriculum Item Status Report for User 47043 09/15/2021 List of Justifications for Continued Operations (JCOs) for CY 07/01/2021 2021 Certificate Certification of Working Weights 05/28/2021 Plant Changes List of Plant Changes in CY 2021 08/20/2021 Procedures ADM-00006 Administrative Procedure for Documentum REDS Version Documents 33.0 ADM-00008 Control of Operator Aids in Richland Operations Version 8.1 AID-10277 Reference 583 EdgeTech Dew Point Monitor Model Version 4.0 COM.AIR AID-10340 Reference 1003 GSE Model 350 Digital Weight Indicator Version 3.0 With Various Weight Platforms E04-05-01 Nuclear Criticality Safety Standards Version 18 E10-08-002 Organization and Administration Version 7.0 E10-08-009 Environmental Protection Version 4.0 E12-03-058 Incident Investigation/Corrective Action Audit Version 4.0 9

Inspection Type Designation Description or Title Revision or Procedure Date E12-03-063 Other QA Elements Audit Version 4.1 MCP-30324 Richland Procedure Writers Guide Version 14.1 MCP-30379 Construction or Modification Change Control Version 17.0 MCP-30383 Preventive Maintenance Version 5.3 MCP-30572 Line 2 ADU UO2 Powder Production (System 90) Controls Version 6.1 Design Description SOP-40276 Calciner Operation - ADU Line 2 Version 24.1 SOP-40789 Work Order Instructions Version 19.0 SOP-40791 Maintenance Work Permit (MWP) & Pre-Job Briefing (PJB) Version 18.0 SOP-40839 Instrument Repetitive Maintenance (IRM) Version 14.0 SOP-40841 Preventive Maintenance (PM) Version 11.0 SOP-41068 Training and Qualification Version 3.1 Self- 2019 Biannual Chemical Safety Audit (2nd Interval) 10/25/2019 Assessments Checklist for Procedure Audit 10/28/2020 2020 Biannual Chemical Safety Audit (2nd Interval) 10/30/2020 2021 Biannual Chemical Safety Audit, Part 1 04/07/2021 NCS Audit Schedule for 2021 EHS&L AUDIT/INSPECTION SCHEDULE 2020 Biannual Chemical Safety Audit, Part 1 04/13/2020 Work Orders 13444456, US58510-01 IROFS CALCINER L2 LUBRICATION Various 13482450, 13479070, 13474804, 13518893, 13515573 13474805 PM004702 AIRLOCK ROTARY 12MO EL 09/18/2020 13474806 PM004701 AIRLOCK ROTARY 12MO MWHZ 09/28/2020 10

Inspection Type Designation Description or Title Revision or Procedure Date 13494328 C090P001 - L2 U02 POWDER INTERLOCKS 6MO RE 03/02/2021 13515283, US19411-93 IROFS SCALE CALCINER DROP DRUM Various 13488020, WEIGHT UO IRM data: 80 DS .066, RED, 1012, C 13467442, 13444456 13515574, US58525-02 IROFS HYGROMETER CALCIN L2 CAL Various 13488295, DROP HYGR IRM data: 5.0 MIA-101, RED, 583, C 13467441, 13444455, 13519411 Manual Call C090I002 08/02/2021 13522878 C355I001 - Scale PWDR STRG BLEU 3 MO IN (Scale - 09/15/2021 IROFS - Barrel Powder Storage BLEU) 13522889 C355P003 - I3E Primary Roof Leak Water Alarms 6-month 09/14/2021 Interval 88070 Corrective CR-2021-0973 Triennial Configuration Management Assessment Findings 04/26/2021 Action and Observations Documents Drawings 08537-GO-08 General Outline 6 Ton Model E Liquid Carbon Dioxide 10/06/08 Storage Unit 08537-SCH-08 Piping Schematic 6 Ton Model E Liquid Carbon Dioxide 10/06/08 Storage Unit CSA-607,590 Horn Rapids Rd Site General Arrangement Line 6 Pelletizing 006.F CSA-607,590 Horn Rapids RD Site General Arrangement Line 6 006.B Pelletizing CSA-607,590 17 CSA-611065 ADU Process Cylinder Wash P & ID 020.C CSA-611070 ADU Process P & ID 018 CSA-611080, Sheet ADU Process Uranium Recovery P & ID 012 1

CSA-611080, Sheet ADU Process Uranium Recovery P & ID 009 7

CSA-611080, Sheet ADU Process Uranium Recovery P & ID 009 8

CSA-611080, Sheet ADU Process Uranium Recovery P & ID 019 11

Inspection Type Designation Description or Title Revision or Procedure Date 9

CSA-611375 BLEU Project Soft Boat Loader #7 BLEU P&ID 002.E CSA-611375 BLEU Project Soft Boat Loader #7 BLEU P 7 ID 002.B CSA-611395, Sheet Line 6 Pellet Grinding and Inspection P&ID 006.C 1

CSA-611395, Sheet Line 6 Grinder Pellet Grinding and Inspection P&ID 004.C 2

CSA-611395, Sheet 001.C 3

CSA-611395, Sheet -.A 4

CSA-611395, Sheet -.A 5

CSA-611950 Nitric Acid Storage & Distribution System 013 CSA-611960 Ventilation Duct System K31 Flow Diagram 008.A CSA-614937 Facilities Waste & Bucket Storage Grid Location -.A CSA-614937 Facilities Waste & Bucket Storage Grid Location -.A CSA-618159 Ceramics GAD Boat Loader Assembly 00B CSA-618167 GAD Pellet Press EMF-602683 One Line Diagram North UO2 Building Distribution Panel "B- 019.A 1"

EMF-606529 UF6 Line 2 Cylinder Wash Detail Diagrams and Schematics 001.A EMF-6161783 Room 100 CO2 Detection Panel EMF-6161783, Line 6 PBL CO2 Remote IO Power Distribution Sheet 509 EMF-6161783, Line 6 PBL CO2 Remote IO Inputs and Outputs Sheet 817 EMF-616783 Line 6 PBL CO2 Remote IO Panel Layout EMF-616783 Room 157 CO2 Detection Panel EMF-617056, Sheet BLEU Conversion Oxide Pellet Building One-Line Diagram 001.A 001 EMF-618022 Line 3 Grinder Line Boat Dumper 000 EMF-618025 Boat Inverter Assembly Boat Inverter Enclosure 000 12

Inspection Type Designation Description or Title Revision or Procedure Date EMF-618053-34 Sheet Rotator Assembly Spacer 000 EMF-618157 GAD Boat Inverter GAD Inverter Assembly A EMF-618160 Soft Boat Loader GAD Enclosure Assembly 00B Engineering ECN 8909 Line 6 Press Install 4/9/20 Changes ECN 8910 COE-GD Grinder Line Install 9/23/19 ECN 8911 IX Column Demo & Prep 10/1/19 ECN 8921 Cylinder Wash Snorkel Improvements 9/8/20 Miscellaneous E10-08-011 SNM-1227-Chapter 11 Management Measures 2.1 Procedures MCP-30131 Safety/Licensing Evaluation of Facility Changes 12 MCP-30379 Construction or Modification Change Control 17 MCP-30379 A Construction or Modification Change Control -Initiation 5.1 MCP-30379 B Construction or Modification Change Control -Planning 3.4 MCP-30379 C Construction or Modification Change Control - Execution 9 MCP-30379 D Construction or Modification Change Control - Controlling 7 MCP-30379 E Construction or Modification Change Control - Closure 4.1 MCP-30383 Preventive Maintenance 5.3 SOP-40789 Work Order Instructions 19 SOP-40791 Maintenance Work Permit (MWP) & Pre-Job Briefing (PBJ) 18 SOP-40839 Instrument Repetitive Maintenance (IRM) 14 SOP-40841 Preventative Maintenance (PM) 11 Self- FRA_D3SEP_IG_21- 21_014_Richland_Configuration_Management_Debriefing 4/26/2021 Assessments 014 FRA_D3SEP_IG_21- Framatome Richland - Configuration Management Program - 6/2/2021 014_IR Inspection from April 20th to 26th 2021 MMD-20-001 Annual Configuration Control Audit Report -- 2020 12/22/2020 SA_2020-0006 2020 Annual Configuration Control Audit 12/29/2020 13

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