ML23202A202
| ML23202A202 | |
| Person / Time | |
|---|---|
| Site: | Framatome ANP Richland |
| Issue date: | 07/24/2023 |
| From: | Eric Michel NRC/RGN-II/DFFI |
| To: | Stephens L Framatome |
| References | |
| IR 2023002 | |
| Download: ML23202A202 (1) | |
Text
Mr. Lance Stephens Site Manager Framatome Inc.
2101 Horn Rapids Road Richland, WA 99354
SUBJECT:
FRAMATOME-RICHLAND - CORE INSPECTION REPORT 07001257/2023002
Dear Mr. Stephens:
This letter refers to the U.S Nuclear Regulatory Commission (NRC) inspection activities conducted from April 1 to June 30, 2023, for the Framatome-Richland fuel facility. On April 26 and June 15, the results of the inspections were discussed with you and other members of your staff. The results of the inspections 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. To the extent possible, your response should not include any personal privacy or proprietary information so that it can be made available to the public without redaction.
Sincerely, 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 July 24, 2023 Signed by Michel, Eric on 07/24/23
SUNSI Review x
Non-Sensitive
Sensitive x
Publicly Available
Non-Publicly Available OFFICE RII/DFFI RII/DFFI RII/DFFI NAME C. Taylor G. Goff E. Michel DATE 07/21/2023 07/24/2023 07/24/2023
Enclosure U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number:
07001257 License Number:
SNM-1227 Report Number:
07001257/2023002 Enterprise Identifier:
I-2023-002-0065 Licensee:
Framatome Inc.
Facility:
Framatome-Richland Location:
Richland, WA Inspection Dates:
April 24 to 26, 2023 June 12 to 15, 2023 Inspectors:
L. Cooke, Fuel Facilities Inspector G. Goff, Fuel Facilities Inspector N. Peterka, Senior (Sr.) Fuel Facility Project Inspector T. Shewmaker, Fuel Facilities Inspector (trainee)
P. Startz, Fuel Facilities Inspector C. Taylor, Sr. Fuel Facility Project Inspector Approved By:
Eric C. Michel, Chief Projects Branch 2 Division of Fuel Facility Inspection
2
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a core inspection at Framatome 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 during this inspection.
Additional Tracking Items Type Issue Number Title Report Section Status Unresolved Issue (URI)
URI 07001257/2022-004-02 MURS Furnace Electrical Hazard 88072 Open
3 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 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 Title 10 of the Code of Federal Regulations (10 CFR) 70 including 70.61, 70.62, 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 safety (NCS), fire protection, and chemical safety based on the information provided in the integrated safety analysis summary. The inspectors conducted a general plant tour of each major plant operating area. The process areas and accident sequences selected for review are listed below:
UO2 - UF6 cylinder washing (combine w/ADU) - systems 065 and 070 -
accident sequences: 065-201, 065-211, 065-214, 065-217, 065-1.1, 065-1.2, 065-1.4, 065-1.5, 065-1.5.1, 065-1.6, 065-1.7
UO2 - ADU (combine w/cylinder washing) - systems 080 and 090 - accident sequences: 080-3.22, 080-3.23, 080-4.1, 080-4.18, 080-4.19.1, 080-4.19.2, 080-6.3, 090-6.4, 090-6.5.2, 090-9.1, 090-10.1, 090-10.2, and 090-10.3
UO2 - storage & lube press feed - systems 350 and 360 - accident sequences:
322-2.1.4, 360-4.2, and 120-3.1
4 Review of Safety Controls and Related Programs (IP Section 02.02)
The inspectors reviewed information related to administrative, engineered, and passive 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 104, administrative control (AC)
IROFS 229, active engineered control (AEC)
IROFS 317, passive engineered control (PEC)
IROFS 403, PEC
IROFS 1505, PEC
IROFS 1508, PEC
IROFS 2202, enhanced administrative control (EAC)
IROFS 2230, PEC
IROFS 2231, PEC
IROFS 2348, PEC
IROFS 3507, PEC
IROFS 6213, AEC 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 applicable sections 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
7 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:
reviewed implementation of management measures for IROFS reviewed to include procedures, surveillances, functional testing, calibrations, corrective actions, and training
reviewed implementing procedures for IROFS (see Documents Reviewed section)
reviewed drawings for the ADU area, BLEU 45-gallon drum tumbler station, and the SURF raffinate treatment TK-361A/B, TK-362 (see Documents Reviewed section)
observed maintenance/functional testing of:
o IROFS 229 o
IROFS 230 o
IROFS 243 o
IROFS 2348
interviewed licensee personnel and reviewed the screening process for determining IROFS 243 was degraded
reviewed the corrective action for degraded IROFS 243
reviewed management control procedures and standard operating procedures for the systems identified in section 02.01 (see Documents Reviewed section)
reviewed E-14-01-007, Hazards Analysis - UO2 ADU Conversion Facility and Miscellaneous Ancillary Systems
reviewed the following nuclear safety analyses:
o E04-NCSA-065, Cylinder Wash Operations o
E04-NCSA-080, ADU Uranium Recovery o
E04-NCSA-090, UO2 Powder Production o
E04-NCSA-163, Industrial Waste Water Treatment Facilities 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 applicable sections of the license application. Specifically, the inspectors conducted the following:
reviewed monthly NCS audits from January 2022 through April 2023 (see Documents Reviewed section)
reviewed condition reports (CRs) related to the ADU, cylinder wash, storage and lube press feed systems (see Documents Reviewed section)
reviewed qualification status of operators responsible for implementing the selected IROFS for ADU, cylinder wash, storage and lube press feed systems
reviewed qualification status for a sample of operators on duty June 12 and June 13, 2023
reviewed management changes in the operations department and the qualification requirements versus personnel qualifications
reviewed maintenance records and work orders for selected IROFS (see Documents Reviewed section)
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reviewed justification for continued operation under compensatory measures: JCO 2022-003, 2022-004, and 2022-005
reviewed CRs for selected IROFS (see Documents Reviewed section)
interviewed the operations manager regarding safety, responsibilities of staff, safety conscious work environment, and employee assistance program
observed daily maintenance planning meetings
observed daily operations plan-of-the-day meetings FACILITY SUPPORT 88051 - Evaluation of Exercises and Drills The inspectors observed and evaluated the licensees graded biennial exercise conducted on April 26, 2023, as well as briefings and critiques involving both onsite and offsite participants, to verify compliance with 10 CFR 70.22(i)(3)(xii) and the emergency plan. The scenario involved a leak at a large ammonium hydroxide tank which resulted in a chemical spill that accumulates in the spill basin, responders dispatching an entry team, and consideration of protective actions downwind of the event.
Exercise Planning (IP Section 02.01)
The inspectors reviewed the emergency exercise scenario, discussed the exercise objectives with licensee personnel, observed controller meetings, and walked down the plant areas before the exercise to verify compliance with the emergency plan, emergency plan implementing procedures, and 10 CFR 70.22(i)(3)(xii). The inspectors reviewed or observed the following:
the frequency of exercises conducted by the licensee
the scenario as it related to probability for occurrence at Framatome and to testing all elements of the emergency plan
no pre-staging of equipment in preparation for the exercise
duties and responsibilities for exercise personnel including controllers, evaluators, and observers
the controllers' meeting for the emergency exercise
the objectives of the exercise and the expectations from responders
the post-drill critique for the emergency exercise Exercise Execution and Emergency Plan Implementation (IP Section 02.02)
The inspectors observed the initiation of the emergency exercise, the activation of the emergency operations center (EOC) and plant emergency organization, classification of the event, notification of offsite response organizations, establishment of the incident command post, implementation of field response teams, and reviewed onsite and offsite communications, releases and notifications to verify compliance with the emergency plan, emergency plan implementing procedures, and 10 CFR 70.22(i)(3)(xii). The inspectors observed and reviewed the following:
the licensees analysis of plant conditions including assessment and classification of the accident scenario within the allowable time limits
staffing for all EOC/emergency organization positions
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protective action recommendations implemented by the EOC/emergency organization
drafting of offsite notifications including a review of content and time of issuance
onsite communication to occupational workers as it related to protective action recommendations
occupational workers participation in protective actions and the process to conduct personnel accountability
press release approval and issuance
emergency director control of the EOC/emergency organization
drill dose assessor use of dose software
response coordinators recommendations regarding conditions for terminating the event and restarting normal operations
recovery and re-entry recommendations implemented by the EOC/emergency organization
members of the licensees emergency response team assembly at designated assembly areas and the arrival of offsite emergency responders to include the Richland Fire Department incident commander
response to emerging situations to address the exercise scenario and meet the exercise objectives
the incident commander command and control of the emergency response team and coordination of actions with offsite emergency responders Critiques, Exercise Control, and Identification and Resolution of Problems (IP Section 02.03)
The inspectors observed the staff critiques of the emergency exercise and reviewed the licensees related corrective action program entries to verify compliance with the emergency plan, emergency plan implementing procedures, and 10 CFR 70.22(i)(3)(xii). The inspectors reviewed and observed the following:
critiques conducted by the licensee in which both licensee participants and offsite responders provided comments
discussions pertaining to the satisfying of all objectives of the emergency exercise
documented deficiencies identified during critiques including items planned for entry into the licensees corrective action program INSPECTION RESULTS No issues were identified.
EXIT MEETINGS AND DEBRIEFS The inspectors verified no proprietary information was retained or documented in this report.
On April 26 and June 15, 2023, the inspectors presented the inspection results to Lance Stephens and other members of the licensee staff at an exit meeting.
8 DOCUMENTS REVIEWED Inspection Procedure Type Designation Description or Title Revision or Date Wastewater Treatment JCO Calculations 12/12/2022 LIMS 596660 Analytical Services Layout for Miscellaneous Liquids 12/12/2022 Calculations LIMS 596685 Analytical Services Layout for Miscellaneous Liquids 12/12/2022 Corrective Action Documents CR-2022-2106 CR-2022-3171 CR-2022-3238 CR-2022-3298 CR-2023-068 CR-2023-1186 Various Various Corrective Action Documents Resulting from Inspection CR-2023-1466 Degraded IROFS-243 06/12/2023 CSA-611270 Scrap UN Recovery Fac Raffinate Treatment TK-361A/B, TK-362 Process & Inst Diagram Revision 0 Drawings CSA-614931 ADU Area and BLEU 45-Gallon Drum Tumbler Revision 0 E-14-01-007 Hazards Analysis - UO2 ADU Conversion Facility and Miscellaneous Ancillary Systems Version 30 E04-NCSA-065 UF6 Cylinder Washing Operation Version 13.0 E04-NCSA-080 ADU Uranium Recovery Version 25.0 E04-NCSA-090 UO2 Powder Production Version 18.0 E04-NCSA-163 Industrial Waste Water Treatment Facilities (IROFS 2348)
Version 36.0 JCO-2022-003 ARF Detector Replaced with Lab Analysis 12/12/2022 JCO-2022-004 Batch Process for ARF Bypass 12/14/2022 Engineering Evaluations JOC-2022-005 Cylinder Recertification Ignore 714 Alarm 12/15/2022 88020 Miscellaneous Print out of pressure transmitter replacements since CY 2020 06/14/2023
9 LU 2189 30B Cylinder Recertified 05/2023 30B Cylinder Recertification Follower Card 05/30/2023 Wash and Valve Follower for Cylinder LU 1122 06/12/2023 E-15 2.14 ARF and Industrial Waste Water Treatment System Revision 21 E15-01-2.9A UO2 Building Revision 20 Miscellaneous FRM-E12-01-007-A -
JCO #2204 Justification of Continued Operation Under Compensatory Safety Measures (E12-01-007) 12/14/2022 E-12-01-007 Justification for Continued Operation Under Compensatory Safety Measures Revision 8 E04-05-01 Nuclear Criticality Safety Standards Version 19.0 E04-NCSS-G01 NCS Guide Rules and Generic Program Regulations Revision 24 E12-03-058 Incident Investigation/Corrective Action Audit Version 5.0 EO4-NCSS-G06 Fire Prevention and Firefighting Revision 32 MCP-30324 Richland Procedure Writers Guide Version 16.0 MCP-30325 Instrument Repetitive Maintenance (IRM)
Version 19.0 MCP-30340 Essential Material Class I: 45-Gallon Powder Containers Version 9.0 MCP-30383 Preventive Maintenance Version 6.0 MCP-30448 Cylinder Wash Controls Design Description Version 8.0 MCP-30455 UNH Powder Dissolution (System 120) Controls Design Description Version 11.0 MCP-30488 UO2 Pellet Dissolution (System 190) Controls Design Description Version 4.0 MCP-31334 Ortec and Mirion Automated Assay Systems Version 1.0 SOP-40228 Uranium Conversion and Recovery Operation Rules Version 24.0 SOP-40233 Blending Powder Additives into NO2 Powder Drums Version 18.0 SOP-40234 Dry Powder Blending, Handling and Labeling of Poisoned 45-Gallon Drums and Safe Batch Containers Version 16.0 88020 Procedures SOP-40259 UF6 Cylinder Wash Operation Version 46.0
10 SOP-40315 Recertification Testing and Inspection of UF6 Cylinders Version 26.0 SOP-40486 Richland Operations, General Rules Version 39.0 SOP-40520 UO2 (Room 104A) Drum Tumbler and Bucket Tumbler Operation Version 13.0 SOP-40531 Blending Powder Additives into 45-gallon Powder Drums in Line 6 Version 13.0 SOP-40789 Work Order Instructions Version 20.0 SOP-40791 Maintenance Work Permit (MWP)
& Pre-Job Briefing (PJB)
Version 20.0 SOP-40841 Preventive Maintenance (PM)
Version 12.0 SOP-40920 Items Relied on For Safety (IROFS) and Equipment Essential to Safety Version 9.0 SWI-50235A Operating the Bucket Tumbler Version 2.0 Self-Assessments E04 202201,
- 202202, 202303,
- 202204, 202205,
- 202206, 202207,
- 202208, 202209,
- 202210, 202211,
- 202212, 202301,
- 202302, 202303, 202304 NCS Monthly Audits Various 13561202 and 13561203 CG81P003-008 BAR BT CART 1YR MWHZ Revision 10.0 13575784 C350I001 SCALE PWDR STORAGE 1Y CAL IN Revision 2.0 13587704 C120P001 UNH OVERFLOW/VENTS/DOOR 6MO PF Revision 12.0 Work Orders
- 13602765, 135987091,
- 13594932, and 13591011 CG06P001 FIRE SAFETY INSPECTION 1MO OPCH Revision 10.0
11 13603015 and 13556439 C360P003-0001 TUMBLR DRUM DRAIN 1Y OPCH Revision 1.0 13605950 C350P002 PWDR STRG MOIST PROTECT 6MO IN Revision 3.0 13606011 C490I010 NIMS SCALE WIT-60005 6 MO IN Revision 2.0 13606266 C350P001 RACKS POWDER STORAGE 1Y MW Revision 2.0 13606439 and 13578582 CG81P002-0009 Barrel Restrain Bars 1Y EL Revision 10.0 C080I016 (IROFS 6213)
TEMP SENSOR TT-16701 1 YR IN 05/09/2021 C080I016 (Manual Call) (IROFS 6213)
TEMP SENSOR TT-16701 1 YR IN 11/16/2021 C080I017 (IROFS 6213)
TEMP SENSOR TT-16801 1 YR IN 05/22/2022 C080I017 (IROFS 6213)
TEMP SENSOR TT-16801 1 YR IN 05/23/2023 C080I017 (Manual Call) (IROFS 6213)
TEMP SENSOR TT-16801 1YR IN 05/09/2021 C080I017 (Manual Call) (IROFS 6213)
TEMP SENSOR TT-16801 1YR IN 11/16/2021 C080I018 (IROFS 6213)
TEMP SENSOR TT-16901 1 YR IN 05/23/2023 C080I018 (IROFS 6213)
TEMP SENSOR TT-16901 1 YR IN 05/22/2022 C080I018 (Manual Call) (IROFS 6213)
TEMP SENSOR TT-16901 1 YR IN 11/16/2021 C080I018 (Manual Call) (IROFS 6213)
TEMP SENSOR TT-16901 1 YR IN 05/09/2021
12 C080P016 (IROFS 6213)
ADU IX HIGH TEMP. SHUTOFFS 12MO IN 08/13/2022 C080P016 (IROFS 6213)
ADU IS HI TEMP SHUTOFF 12MO IN 08/31/2021 C080P016 (IROFS 6213)
ADU IX HIGH TEMP. SHUTOFFS 12MO IN 08/31/2020 C080P016 (Manual Call) (IROFS 6213)
IROFS TANK TK 156 ION EXCHANGE COLUMN 05/28/2021 C090I002 (IROFS 2204)
HYGROMETER CAL-DROP-1 Y2 CAL IN 07/12/2022 C090I002 (IROFS 2204)
HYGROMETER CAL-DROP-1 Y2 CAL IN 01/20/2023 C090I002 (Manual Call) (IROFS 2204)
HYGROMETER CAL-DROP-1 Y2 CAL IN 04/11/2023 C090I003 (IROFS 2202)
THERMOCOUPLE CAL Y2 CALIB IN 04/29/2023 C090I003 (IROFS 2202)
THERMOCOUPLE CAL Y2 CALIB IN 10/29/2022 C090I004-0001 (IROFS 2202)
XMITTER TTA-225A Y2 CAL IN 12/10/2022 C090I004-0001 (IROFS 2202)
XMITTER TTA-225A Y2 CAL IN 12/10/2022 C090I007-0001 (IROFS 2202)
XMITTER TTA-225B Y2 CAL IN 12/10/2022 C090I008-0001 (IROFS 2202)
XMITTER TTA-225C Y2 CAL IN 12/10/2022 C090I009 (IROFS 2205)
HYGROMETER CAL-DROP-2 Y2 CAL IN 01/20/2023
13 C080P016 (IROFS 6213)
ADU IX HIGH TEMP. SHUTOFFS 12MO IN 08/13/2022 C090P001 (IROFS 2202, 2204, 2205, 2011)
L2 UO2 POWDER INTERLOCKS 6MO RE 02/28/2023 C090P001 (IROFS 2202, 2204, 2205, 2011)
L2 UO2 POWDER INTERLOCKS 6MO RE 08/10/2022 C100P001 (IROFS 2231)
L2 OVERFLOW / VENTS 12MO PF 03/17/2022 C100P001 (IROFS 2231)
L2 OVERFLOW / VENTS 12MO PF 03/02/2023 C163P107 (IROFS 2348)
VALVE SHUTOFF FCV-712-4 IX REGEN PUMPOUT 2MO OPCH 06/13/2023 C270I007 (IROFS 229)
PRESSURE XMTR PIT-00101 6 MO IN 06/12/2023 C270I008 (IROFS 230)
PRESSURE TRANSMIT'R PIT-00102 6 MO IN 06/12/2023 C270I010 (IROFS 243)
PRESSURE XMTR PIT-361A4 6 MO IN 06/12/2023 C270I010 (IROFS 243)
PRESSURE XMTR PIT-361A4 6 MO IN 06/17/2022 C270I010 (IROFS 243)
PRESSURE XMTR PIT-361A4 6 MO IN 12/20/2022 C270P001 (IROFS 243)
SURF INTERLOCK CHECK 1 YR IN 11/05/2021 C270P001 (IROFS 243)
SURF INTERLOCK CHECK 1 YR IN 11/30/2022 C270P001 (IROFS 243)
SURF INTERLOCK CHECK 1 YR IN 11/15/2020 C720P001 (IROFS 736)
FUNCTIONAL TEST UN 1 YR RE 10/25/2022 S065I004 Crane Scale WIT-1 05/08/2023 WO 11531802 Cylinder Wash Water Tank 04/01/2022 WO 11533958 Cylinder Wash TK 245 Bladder 04/22/2022 WO 11547078 Cylinder Wash DIW Bladder Replace 09/11/2022 WO 11547312 Cylinder Wash 245 Tank Leak 09/13/2022
14 C080P016 (IROFS 6213)
ADU IX HIGH TEMP. SHUTOFFS 12MO IN 08/13/2022 WO 13547993 C065P007 UF6 Cyl Wash Hardware 6Mo OPCH 03/28/2022 WO 13571926 C065P007 UF6 Cyl Wash Hardware 6Mo OPCH 09/01/2022 WO 1359293 C065P007 UF6 Cyl Wash Hardware 6Mo OPCH 03/01/2023 WO 13605016 C065P007 UF6 Cyl Wash Hardware 6Mo OPCH 05/08/2023 CR-2021-2499 various various CR-2022-1239 CR-2022-1474 CR-2022-2657 CR-2020-2392 CR-2021-0867 Corrective Action Documents CR-2022-2657 E08-03-1.1 Classifying an Emergency Version 8.0 E08-03-2.1 Determining Protective Actions Version 5.0 E08-03-3.1 Plant Emergency Director Version 13.0 E08-03-3.12 Central Guard Station Officer Version 6.0 E08-03-3.8 PERT Incident Commander Version 8.0 E08-03-4.1 Incident Notification Form Version 8.0 E08-03-4.5 Plant Public Address Emergency Message Format Version 5.0 E08-03-6.
Radiological Field Team Procedures Version 1.0 E08-03-6.2 Chemical Field Team Procedure Version 7.0 E08-03-6.3 Personnel Monitoring Version 4.0 E08-03-6.5 Chemical Spill Response Plan Version 8.0 88051 Procedures E08-03-8.7 Emergency Action Guides Version 4.0