ML24026A279

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Framatome - Richland – Integrated Inspection Report 07001257/2023004
ML24026A279
Person / Time
Site: Framatome ANP Richland
Issue date: 01/31/2024
From: Eric Michel
NRC/RGN-II/DFFI/FFB2
To: Stephens L
Framatome
References
EN56851, EN56904 IR 2023004
Download: ML24026A279 (24)


Text

EN56851 EN56904 Lance Stephens Site Manager Framatome Inc.

2101 Horn Rapids Road Richland, WA 99354

SUBJECT:

FRAMATOME - RICHLAND - INTEGRATED INSPECTION REPORT 07001257/2023004

Dear Lance. Stephens:

This letter refers to the U.S Nuclear Regulatory Commission (NRC) inspection activities conducted from October 1, 2023, to December 31, 2023, for the Framatome-Richland fuel facility. On October 26th and November 16th, the results of the inspections were discussed with 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.

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 January 31, 2024 Signed by Michel, Eric on 01/31/24

ML24026A279 X

SUNSI Review X

Non-Sensitive

Sensitive X

Publicly Available

Non-Publicly Available OFFICE RII/DFFI RII/ORA RII/DFFI RII/DFFI NAME G. Goff K. McCurry C. Taylor E. Michel DATE 1/29/2024 1/ 31/2024 1/26/2024 1/31/2024

Enclosure U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number:

07001257 License Number:

SNM-1227 Report Number:

07001257/2023004 Enterprise Identifier:

I-2023-004-0060 Licensee:

Framatome Inc.

Facility:

Framatome Inc. - Richland Location:

Richland, WA Inspection Dates:

October 23-26, 2023, and November 13-17, 2023 Inspectors:

G. Goff, Fuel Facilities Inspector K. McCurry, Technical Assistant 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 core inspections 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 Type Issue Number Title Report Section Status WER 07001257/2023-002-01 Flexible connector on the K-69 (MERF) exhaust duct downstream of the final HEPA filter degraded (EN56851) 88020 Open

3 PLANT STATUS During the inspection period, routine fuel manufacturing operations and maintenance activities were conducted in the fuel processing areas, Scrap Uranium Recovery Facility (SURF), and Specialty Fuels (SF). 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.

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 88015 - Nuclear Criticality Safety The inspectors evaluated selected aspects of the licensees nuclear criticality safety (NCS) program to verify compliance with selected portions of Title 10 of the U.S. Code of Federal Regulations (10 CFR) Part 70, "Domestic Licensing of Special Nuclear Material," including 70.24, 70.50, 70.61, 70.62, and Appendix A; Chapter 3, Integrated Safety Analysis (ISA) and ISA Summary, Chapter 5, Nuclear Criticality Safety, and Chapter 11, Management Measures, of the license application; and applicable licensee procedures.

Criticality Analysis (IP Section 02.01)

The inspectors interviewed licensee staff and reviewed nuclear criticality safety analyses (NCSAs), and associated assumptions and calculations, to verify compliance with 10 CFR Part 70 and applicable sections of the license application. Specifically, the inspectors interviewed licensee staff and reviewed the following NCSAs for the following referenced areas and systems:

E04-NCSA-370, "UO2 Pellet Pressing," Version 19.0 E04-NCSA-380, "Pellet Sintering Area," Version 11.0 E04-NCSA-390, "UO2 Pellet Grinding & Inspection," Version 24.0 For the NCSAs listed above, the inspectors reviewed:

recent revisions including changes that will be adopted to process an enrichment greater than 5 weight (wt.)%, changes in items relied on for safety (IROFS), and changes to parameter limits;

4 all credible accident sequences along with assigned failure frequency, probability, and duration index numbers, application of the double contingency principle, and demonstration that the likelihood of each scenario remained highly unlikely with credited IROFS; and the basis for normal, credible abnormal, and noncredible accident scenarios.

The inspectors also interviewed licensee staff and reviewed:

E04-NCSA-163, "Industrial Wastewater Treatment Facilities," Version 36.0, specifically the accident sequences and management measures impacted by the IROFS moved from the Engineering Laboratories and Office to the Ammonia Recovery Facility E04-NCSA-960, "HVAC Exhaust Systems," Version 42.0, specifically the IROFS covered by the NCS monthly audit and system walkdown Criticality Implementation (IP Section 02.02)

The inspectors selected passive engineered, active engineered, and administrative controls from the licensees ISA summary and NCSAs to verify proper implementation through a review of process and system descriptions, plant walkdowns, and operator interviews to verify compliance with 10 CFR 70 and applicable sections of the license application. Specifically, the inspectors interviewed system operators and engineers, walked down the systems and areas, and reviewed selected management measures for the following controls associated with the NCSAs listed above:

Passive Engineered Controls (PECs) including IROFS 403, IROFS 1618, IROFS 1627, IROFS 1817, IROFS 2505, IROFS 2517, IROFS 2517.10, IROFS 2606, and IROFS 2608; Active Engineered Controls (AECs) including IROFS 1621, IROFS 1622, IROFS 2326, and IROFS 2609; Administrative Controls (Admin) including IROFS 1604.10, IROFS 1617, IROFS 1808, IROFS 1824, IROFS 1826.10, IROFS 2107, and IROFS 2610; and management measures including operating procedures, postings, calibration records, and functional testing.

Criticality Operational Oversight (IP Section 02.03)

The inspectors assessed the NCS staffs oversight of plant operators, procedures, and operations of systems involving special nuclear material to verify compliance with 10 CFR 70 and applicable sections of the license application. Specifically, the inspectors performed the following activities:

conducted system walkdowns of the UO2 pellet pressing, sintering, grinding, and inspection areas (Systems 370, 380, and 390) with NCS staff to verify proper knowledge of the associated operations and NCS controls concerning criticality hazards; interviewed NCS staff regarding monthly audits and observed the associated NCS engineer walkdown of HVAC Exhaust Systems (NCSA 960);

5 witnessed interactions between NCS staff and operators on the floor during system walkdowns and interviewed operators regarding NCS safety; reviewed training material and exams developed by the NCS staff for operators, engineers, and supervisors regarding criticality worker safety; and interviewed NCS staff to determine no changes were made to the validation report since the last NRC NCS inspection, and there were no maintenance activities planned related to NCS controls the week the inspectors were onsite.

Criticality Programmatic Oversight (IP Section 02.04)

The inspectors reviewed NCS program procedures, audits, and NCS staff qualifications to verify compliance with 10 CFR 70 and applicable sections of the license application. Specifically, the inspectors interviewed licensee NCS staff and reviewed the following documents:

recently revised NCS procedure E04-09-001, "HRR Criticality Accident Alarm System Coverage Demonstration," Version 8.0 recently revised NCS procedure E12-03-006, "Criticality Alarm System Audits &

Appraisals," Version 6.0 monthly NCS audit/inspection reports from December 2022 to August 2023 that covered a sample of process systems, preventive maintenance records, and NCS infraction trends training records for newly qualified NCS staff including assessments for criticality safety analysts and specialists and criticality safety skills practical application confirmation for employees Criticality Incident Response and Corrective Action (IP Section 02.05)

The inspectors reviewed the licensees criticality accident alarm system (CAAS) and corrective action program (CAP) to verify compliance with 10 CFR 70 and applicable sections of the license application. Specifically, the inspectors observed and/or reviewed the following documents and activities:

for the CAAS, the inspectors reviewed the two recently revised procedures listed above and interviewed NCS staff to determine there was no CAAS related testing, maintenance, or modification activities planned the week inspectors were on-site.

for the CAP, the inspectors reviewed licensee-identified issues related to NCS and the associated corrective actions, extent of conditions, causal analyses, and Appendix A reportability evaluations.

also related to the CAP, the inspectors reviewed and interviewed licensee staff regarding the following condition reports (CRs):

o CR-2023-0068 o

CR 2023-1178 o

CR 2023-1697 o

CR 2023-2004 o

CR 2023-2063 o

CR 2023-2132

6 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, 70.62, 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 safety, radiation safety, fire safety, and chemical safety based on the information provided in the ISA summary and other safety basis documentation. The inspectors conducted a general plant tour of major plant operating area. The process areas and accident sequences selected for review are listed below:

Accident Sequences in the UF6 Recertification Facility o

005-200 - A full or partially full cylinder leading to release of UF6 or hydrofluoric acid (HF) gas, with potential personnel exposure o

005-202 - A full or partially full, "cold" cylinder leading to release of UF6 or HF gas, with potential personnel exposure o

005-1.2 - A full or partially full cylinder UF6 Cylinder with heel and valve leading to a potential criticality Accident sequences in the SURF o

270-2.5 - uranium will sink to the bottom of a UNB (spell-out) storage tank and long-term accumulation may result in a critical mass Accident sequences in the Dry Conversion Facility (DCF) - Powder Preparation and Scrap Download & Hood Operations o

830-1.1.3 - known moisture transferred directly to a blender receiver, sufficiently moderating UOx in the receiver o

830-2.1.3 - known moisture transferred directly to a blender, sufficiently moderating UOx in the blender o

830-2.6.1 - a chemical is added to a Dry Conversion blender, sufficiently moderating UOx in the blender o

830-4.1.5 - failure to place a drum correctly in hood causes spill in an unfavorable geometry inside the hood o

830-4.1.7 - spillage and/or overfill into an unfavorable geometry inside the hood Accident sequences in the Ancillary Systems o

932 failure HIGH of the dual hydrogen pressure regulator system leading toa potential deflagration or explosion to downstream systems o

932 failure LOW of the nitrogen pressure to the gas mixers leading to a potential deflagration or explosion to downstream systems o

932 failure to remove the spool piece in the nitrogen purge line leading to a potential deflagration or explosion to downstream systems o

932 hydrogen into the nitrogen supply system leading to a potential deflagration or explosion to downstream systems

7 Review of Safety Controls and Related Programs (IP Section 02.02)

The inspectors reviewed information related to administrative, enhanced administrative, engineered, and passive safety controls or IROFS for the accident sequences selected in Section 02.01, 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 104.00, operators training for spills, rod/bundle spacing and geometry control, and control of special nuclear material (SNM) if a flood is present, administrative control (Admin)

IROFS 220, density monitor with interlock, active engineered controls (AEC)

IROFS 237, concentration control via sampling (Admin)

IROFS 238, concentration control via sampling (Admin)

IROFS 239, concentration control - TBP volume used tracking alarm (enhanced administrative control (EA)

IROFS 707, operator verifies cylinders washed and valves removed before cylinders are brought into recertification facility (Admin)

IROFS 708, operator verifies cylinder interior prior to recertification and reviews cylinder wash paperwork (Admin)

IROFS 709, operator verifies cylinders not stored intermixed with unwashed cylinders (Admin)

IROFS 741, vent line that prevents positive or negative pressurization of vessels, passive engineered controls (PEC)

IROFS 1014.00, appropriate response to roof leak in DCF (Admin)

IROFS 1044.10, drum in place and lid down interlock (AEC)

IROFS 1103.00, moisture interlock control via monitoring (AEC)

IROFS 1104, low temperature interlock (AEC)

IROFS 1106, moisture probe with alarm, (EA)

IROFS 1108.00, primary barrier control of atmospheric precipitation, (PEC)

IROFS 1109.00, secondary barrier control of atmospheric precipitation (PEC)

IROFS 1116.00, scale interlock limit (AEC)

IROFS 1123.00, second party check of lot weight not to exceed known weight (Admin)

IROFS 1124.00, moderation control via lid interlock (AEC)

IROFS 1139.00, moderation control via process enclosures (hoods) (PEC).

IROFS 3210.00, operator awareness and intervention (Admin)

IROFS 4502.00, procedures control of ignition sources and storage of combustible/flammable materials (Admin)

IROFS 4503.00, independent monthly surveillance to check for ignition sources and storage of combustible/flammable materials (Admin)

IROFS 5102, H2 and N2 pressure sensors with interlock (AEC)

IROFS 5103, H2 and N2 pressure sensors with interlock (AEC)

8 IROFS 5104, maintenance work followed by independent personnel verification of spool piece removal (Admin)

IROFS 5105, manual shutoff valves locked in closed position (Admin)

IROFS 6108, moderation/geometry control by operator awareness and intervention (EA)

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 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. The specific documents reviewed are listed in the "Documents Reviewed" section of this inspection report.

walkdowns performed to verify implementation of active and passive IROFS listed in the section above and observe overall housekeeping practices in process areas accompanied licensee personnel and observed calibration of a scale (IROFS) for pellet recycling observed a pre-job briefing with an off-site contractor on backflow preventers installation walked down IROFS 220 (SURF - mixer/settler) and reviewed maintenance records walked down IROFS 1104 and IROFS 1106 and reviewed maintenance records (System 830) walked down ventilation lines to the storage tanks in the UNB (IROFS 741) and reviewed maintenance records walked down Justification for Continued Operation (JCO)-2023-001 - SURF walked down JCO-2023-003 -ADU calciner line reviewed procedures E12-01-007, JCO Under Compensatory Safety Measures, Version 8 reviewed applicable accident sequences in the NCSAs for the IROFS listed in the section above interviewed the licensee on the ventilation and criticality safety concern for tanks in the UNB interviewed the licensee maintenance technicians and walkdown aspects of the ventilation system in the Modular Extraction/Recovery Facility (MERF) interviewed operations and maintenance staff assigned to perform inspections to verify their knowledge of the requirements associated with their assigned responsibilities and inspections reviewed selected procedures for Systems 005, 830, 270 and 932 (see the Documents Reviewed section below) accompanied recertification operators on a walkdown of the sump, sump receiver tank, and floor sump tank located in the recertification facility to verify design specifications and operability as described in the ISA Summary

9 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. Additionally, the inspectors followed-up on Written Event Reports (WERs) as described below. Specifically, the inspectors conducted the following:

reviewed work orders (WOs) for IROFS and other safety-related equipment (see the Documents section below) reviewed samples of IROFS-related Correction Action Program (CAP) entries for the previous six months such as CR-2023-1544 and CR-2023-1657 reviewed a sample of technician training and qualifications curriculum status for Dry Conversion Powder Prep, Raffinate Processing, UF6 Cylinder Recertification, and SURF Pellet Dissolver reviewed the training curriculum for operators assigned to the operations within the SURF reviewed the training outline and exam for ISA and IROFS attended the plan-of-the-day meetings (maintenance meetings) and the daily production meetings reviewed audit reports for NCS audit/inspection reports performed June 2023 September 2023 reviewed the organizational chart and interviewed the licensee regarding any personnel changes in the areas selected for inspection walkdowns and interviews to review Event Notification56851, regarding a degraded flexible connector on an exhaust duct downstream of the final HEPA filter in the MERF. Inspectors reviewed CR-2023-2684. Reviewed recent MERF preventative maintenance WO 13619195 for Stack Exhaust K69 dated 9/1/23 and dioctyl sebacate (DOS) test WO 13631608 for the MERF final HEPA filter dated 11/17/23. Full corrective action implementation is due by 2nd quarter of 2024.

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 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 modifications involving new processes met the requirements in 10 CFR 70.64.

10 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 8935 - Line 6 Calciner Improvements ECN 8967 - AFM Process Containers - 45 Gallon Powder Drums ECN 8968 - SURF Pellet Dissolver Modifications ECN 8973 - UO2 Sludge Station Modifications ECN 9015 - ARF Assay Replacement Tank 717, 714, 680, and 780 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 change management procedures (management control procedures (MCP) and standard operating procedures (SOP)) to verify the configuration management system was documented in written procedures and the procedures addressed the aspects in 10 CFR 70.72(a):

MCP-30147, Startup Council, Version 9.0 MCP-30379, Construction or Modification Change Control, Version 19.

MCP-30379 A, Construction or Modification Change Control - Initiation, Version 6.0 MCP-30379 B, Construction or Modification Change Control - Planning, Version 4.0 MCP-30379 C, Construction or Modification Change Control - Execution, Version 13.0 MCP-30379 D, Construction or Modification Change Control - Controlling, Version 9.0 MCP-30379 E, Construction or Modification Change Control - Closure, Version 5.0 SOP-40256, ARF Ion Exchange System, Version 19.0 SOP-40258, Sand Filter and Ion Exchange Column Backwash Processing, Version 10.0 SOP-40791, Pre-Job Briefing Procedure, Version 21.0 interviewed licensee staff regarding the plant modifications' purpose, safety review, implementation, post-modification testing, and current performance performed walkdowns of modifications for Line 6 calciner, the improved 45-gallon powder drums, the SURF pellet dissolver, the UO2 sludge station, and the Ammonia Recovery Facility (ARF) gamma monitors on Tank 714, 717, 680, and 780 interviewed licensee staff regarding their evaluation of these modifications provided valid technical bases to determine whether an amendment to the license was required based on the criteria in 10 CFR 70.72(c) reviewed facility documentation associated with the selected changes such as drawings, maintenance records, audits, and NCSAs (see the Documents Reviewed section)

11 reviewed the Summary of Facility Changes submitted by the licensee for modifications made during calendar year 2022 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 other 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 licensee management regarding the impact to existing IROFS and the functionality of additional IROFS reviewed the following maintenance and surveillance records:

o C163I102-0001, Detec Assay Tk714 o

C163I102-0002, Detec Assay Tk714 o

C163I102-0003, Detec Assay Tk714 o

C163I102-0004, Detec Assay Tk714 o

C163I102-0005, Detec Assay Tk714 o

C163I102-0006, Detec Assay Tk714 o

C163P104, IX Feed Interlock Checks o

C260I003, Flowmeter DIT/FIT-33202 o

C260P001, SURF Interlock Check reviewed the following training curriculums:

o HRR-CRT-800001-005, Training Curriculum - Integrated Safety Analysis (ISA) o HRR-CRT-800001-006, Training Curriculum - Items Relied On For Safety o

HRR-CRT-800001-007, Training Curriculum - IROFS Database o

HRR-CRT-800001-008, Training Curriculum - Roles and Responsibilities o

HRR-CRT-800001-009, Training Curriculum - Going Forward reviewed the following condition reports:

o CR-2022-3152 o

CR-2023-2063 o

CR-2023-2132 reviewed recent audits and assessments of the configuration management system:

o MMD-21-003, Annual Configuration Control Audit Report - 2021 o

SCP-23-001, Annual Configuration Control Audit Report - 2022 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:

reviewed the "Evaluation of NRC Pre-Approval" section in each ECN above interviewed the licensee regarding the basis for the determination that no NRC pre-approval was required

12 Records Retention (IP Section 02.05)

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:

operating procedures: SOP-40256, SOP-40258, and SOP-40791 reviewed training records (see Documents Reviewed section below) system drawings: CSA-607590, CSA-611960, CSA-617,136, CSA-617108-001, CSA-618085, DS-DH-19-000, DS-DH-19-001, and other drawings included as part of the ECN packages above INSPECTION RESULTS WER (Open)

Flexible Connector on the K-69 (MERF) Exhaust Duct Downstream of the Final HEPA Filter Degraded (EN56851)

WER 07001257/2023-002-00 88020

==

Description:==

On November 13, 2023, the Framatome-Richland facility reported to the NRC Operations Center that on November 2, 2023, Air Balance technicians, who were testing hood air flows in MERF, determined that these flows were acceptable, but were lower than normal.

After further investigation, one of the flexible connectors (junction boot) between the final HEPA filter bank and the exhaust fan (K69 exhaust system) was identified as being slightly degraded. The licensee notified the Washington Department of Health (WDOH) as required by their air emission license. On November 3rd, the WDOH identified additional degradation on the transition between the process off gas and the exhaust duct.

The licensee determined that although the flow from the inside of the contaminated area was slightly reduced, it remained within acceptable limits. The portion of the exhaust system effected was located in a non-contaminated area (downstream of the final HEPA filter bank) and did not impact the function of the ventilation units ability to maintain an acceptable negative pressure on the system. The licensee determined by surveys no contamination was identified in the affected area.

The initial report to the NRC Operations Center was made per the requirements of 10CFR70 Appendix A (c) - Concurrent reports, because of a report to another regulatory agency.

Licensee Actions: The flexible connector was replaced and tested on November 15th.

2023. In addition, Framatome updated an existing preventative maintenance (PM) procedure to include a step to inspect flexible exhaust connectors for wear/fatigue on a biennial frequency. The licensee identified no apparent health or safety consequences associated with EN56851.

NRC Completed and Planned Closure Actions: Inspectors reviewed the Event Report (EN56851) and the 60-day report (ML23341A216) dated December 7, 2023. The inspectors plan to evaluate corrective actions and maintenance records during a scheduled onsite inspection the 3rd quarter of 2024, therefore, WER 07001257/2023-002-00, "Concurrent

13 Report - Flexible Connector on the K-69 (MERF) Exhaust Duct Downstream of the Final HEPA Filter Degraded (EN56851)" will remain open.

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

On October 26th and November 16th, the inspectors presented the core inspection results to Timothy Tate, Calvin Manning, and other members of the licensee staff.

14 DOCUMENTS REVIEWED Inspection Procedure Type Designation Description or Title Revision or Date 88015 Procedures SOP-40332 Ceramic Operations - UO2 Pres 1, 2, & 3 Rotary Press Operation Version 39.0 88015 Procedures SWI-40258 C Analyzing and Counting Samples Using the Ortec Maestro Gamma Energy Analyzer ARF U Monitor 1 Version 1.0 88015 Radiation Surveys ARF Gamma Scan Standard Count 10/25/2023 88015 Work Orders 13539719 C185I002 Analyzer Uranium 1 YR IN 02/11/2022 88015 Work Orders 13563967 Manual Call IRM C185I002 06/27/2022 88015 Work Orders 13587717 C185I002 Analyzer Uranium 1 YR IN 02/06/2023 88015 Work Orders 13617258 C370P003-0003 Pellet Press L3 500HR MWHz 07/26/2023 88015 Work Orders 13617259 C370P003-0004 Pellet Press L4 500HR MWHz 07/25/2023 88015 Work Orders 13622473 C370P003-0003 Pellet Press L3 500HR MWHz 09/12/2023 88015 Work Orders 13622474 C370P003-0004 Pellet Press L4 500HR MWHz 09/08/2023 88020 Corrective Action Documents CR 2022-3238 Calibration C360I005, Out of Toleration, IROFS 1106.11 12/13/2022 88020 Corrective Action Documents CR 2023-1698 TE-2032 & TE-2036, Were not reading: IROFS 1106 & 1007 07/19/2023 88020 Corrective Action Documents CR 2023-2050 Auto Luber for ADU Calciner Not Working 09/11/2023 88020 Corrective Action Documents CR-2023-1544 SURF PVC Fitting Leak on POG 06/29/2023 88020 Corrective Action Documents CR-2023-1657 Evaluation of Reportability for Safety Incident 2023-001 07/25/2023 88020 Corrective Action Documents CR-2023-1720 Tee Near Solvent Extraction Assembly Appears to be Cracked 07/31/2023 88020 Corrective Action Documents CR-2023-1869 SI-23-002 HF Detector Found Unresponsive 08/18/2023 88020 Corrective Action Documents CR-2023-2684 Degraded Junction boot on Duct Downstream of the HEPA filters, Upstream of the Stack on K69/EU 1513 (MERF) 88020 Drawings CSA - 607, 590 Horn Rapids Road Site General Arrangement for Dry Conversion, Floors 1 - 4 (four drawings)

Revisions 20, 23, 24, and 37

15 Inspection Procedure Type Designation Description or Title Revision or Date 88020 Engineering Changes Engineering Change Notice (ECN) 9060 SURF POG Piping Upgrade 10/19/2023 88020 Engineering Evaluations E04-NCSA-270 SURF Solvent Extraction (SX) and Raffinate Treatment Version 5.0 88020 Engineering Evaluations E04-NCSA-720 Uranyl Nitrate Storage Building Version 10.0 88020 Engineering Evaluations E04-NCSA-820 Dry Conversion Powder Production Process Version 20.0 88020 Engineering Evaluations E04-NCSA-830 Dry Conversion Powder Preparation Version 21.0 88020 Engineering Evaluations E04-NCSS-932 Hydrogen Service System Version 15.0 88020 Engineering Evaluations E04-NCSS-G01 NCS Guide Rules & Generic Program Requirements Version 25.0 88020 Engineering Evaluations E04-NCSS-G06 Fire Prevention and Firefighting Version 23.0 88020 Engineering Evaluations E14-01-010 North Tank Farm and Ancillary Service Systems Version 6.0 88020 Engineering Evaluations E14-01-022 Hazards Analyses - Uranyl Nitrate Building Version 8.0 88020 Engineering Evaluations E15-01-2.20 Part 2 - Chapter 20 - Ancillary Systems (ISA)

Version 12.0 88020 Engineering Evaluations E15-01-2.22 Part 2 - Chapter 22 - Scrap Uranium Recovery Facility (SURF) (ISA)

Version 3.0 88020 Miscellaneous Training curriculum for the SURF Pellet Dissolver 10/9/2019 88020 Miscellaneous Training records for select operators in SURF and in Dry Conversion powder preparation and in Dry Conversion download and hood operations 2023 88020 Miscellaneous ISA and IROFS training outline and exam 03/07/2012 88020 Miscellaneous List of equipment related to IROFS 5102 and 5103 (Hydrogen and Nitrogen valves, switches, and relays) 11/15/2023 88020 Miscellaneous Daily 0820 Meeting (Production Meeting, includes safety) 11/13-14/2023

16 Inspection Procedure Type Designation Description or Title Revision or Date 88020 Miscellaneous HRR Site and Facilities Maintenance Plan of the Day 11/13-14/2023 88020 Miscellaneous JCO#: 2023-001 Justification for Continued Operations Under Compensatory Safety Measures - leaking PVC pipes in SURF 08/02/2023 88020 Miscellaneous JCO#: 2023-003 ADU calciner must be manually greased 09/12/2023 88020 Miscellaneous Maintenance Work Permit (MWP) - 19117 Pre-job brief for fire alarm tests and backflow preventers 11/13/2023 88020 Procedures 1302-03 US Fuel Quality Records Storage and Retention Requirements Revision 7.0 88020 Procedures 1703-76 Issue Evaluation and Causal Analysis Procedure Revision 26.0 88020 Procedures 1703-76-F02 Apparent Cause Analysis Quality Index Scorecard Revision 10.0 88020 Procedures 1703-88 US Fuel Corrective Action Program (Devonway ICAP)

Revision 3.0 88020 Procedures 1723-01 Framatome US Fuel Training Process Revision 13 88020 Procedures ADM-00006 Administrative Procedure for Documentum REDS Documents Version 36.0 88020 Procedures E12-01-003 Environmental, Health, Safety & Licensing Audit and Assessment Program Version 12.0 88020 Procedures MCP-30325 Instrument Repetitive Maintenance (IRM)

Version 20.0 88020 Procedures MCP-30379 Construction or Modification Change Control - Controlling Version 9.0 88020 Procedures MCP-30383 Preventive Maintenance (PM)

Version 7.0 88020 Procedures MCP-30524 Hydrogen Generating and Mixing (System 932) Controls Design Description Version 4.0 88020 Procedures MCP-30536 Dry Conversion Powder Production (System 820) Controls Design Description Version 8.0 88020 Procedures SOP-40020 In-Plant Air Sampling Version 20.0 88020 Procedures SOP-40228 Uranium Conversion and Recovery Operations Rules Version 26.0 88020 Procedures SOP-40259 UF6 Cylinder Wash Operation Version 46.0 88020 Procedures SOP-40292 Dry Conversion Facility - Preparing and Removing UF6 Cylinders Version 23.0 88020 Procedures SOP-40297 Dry Conversion Facility - UF6 General Information Version 12.0 88020 Procedures SOP-40306 Dry Conversion Facility - Automated Blender Lot Makeup Version 18.0

17 Inspection Procedure Type Designation Description or Title Revision or Date 88020 Procedures SOP-40315 Recertification Testing and Inspection of UF6 Cylinders Version 27.0 88020 Procedures SOP-40486 Richland Operations General Rules Version 40.0 88020 Procedures SOP-40886 Working on Nitrogen (N2), Argon (Ar), Hydrogen (H2), H2/N2 and Associated Supply Lines Version 10.0 88020 Procedures SOP-40910 Operation of the Hydrogen Generator System Version 19.0 88020 Procedures SOP-40920 Items Relied On For Safety (IROFS) and Equipment Essential to Safety Version 9.0 88020 Procedures SOP-41143 SURF Mixer-Settler Operation Version 4.0 88020 Procedures SOP-41145 SURF UNB Processing Version 3.0 88020 Procedures SWI-40319B Transfer and Storage of UF6 Cylinders Version 11.0 88020 Self-Assessments Analytical Services (Laboratories) /

Monthly Safety Inspection Inspect for random tools (wires, etc.) hanging on equipment and conduit 08/22/2023 88020 Self-Assessments Analytical Services (Laboratories) /

Monthly Safety Inspection Inspect electrical panels for 3 clearance; inspect for daisy chaining of power strips/extension cords and using extension cords for permanent applications 07/25/2023 88020 Self-Assessments Analytical Services (Laboratories) /

Monthly Safety Inspection Inspect equipment/items stored on shelves (they should be neatly stored) and cabinets/lockers over 6 that open should not have anything on them 06/22/2023 88020 Self-Assessments Analytical Services (Laboratories) /

Monthly Safety Inspection Signs and Tags - readability, appropriate, up-to-date. Verify radiological signs and markings 09/19/2023 88020 Self-Assessments Analytical Services (Laboratories) /

Monthly Safety Observe employees working in manufacturing areas to see if they have gloves with them 10/23/2023

18 Inspection Procedure Type Designation Description or Title Revision or Date Inspection 88020 Self-Assessments E04-07-202306 NCS Audit/Inspection Report - June 2023 Version 1.0 88020 Self-Assessments E04-07-202307 NCS Audit/Inspection Report - July 2023 Version 2.0 88020 Self-Assessments E04-07-202308 NCS Audit/Inspection Report - August 2023 Version 1.0 88020 Self-Assessments E04-07-202309 NCS Audit/Inspection Report - September 2023 Version 1.0 88020 Work Orders 13619195 PM-HVAC K69 Exhaust System MERF 09/01/2023 88020 Work Orders 13631608 DOS TEST K69-5-1 2 YR 11/17/2023 88020 Work Orders WO#: 11468178 DOS Test 05/28/2020 88020 Work Orders WO#: 13497631

/ S932I002 Pressure Switch 03/22/2021 88020 Work Orders WO#: 13530081

/ C270P001 SURF Interlock Check 11/05/2021 88020 Work Orders WO#: 13575623

/ C720P009 Storage Tanks Sample 11/15/2022 88020 Work Orders WO#: 13579237

/ C270P001 SURF Interlock Check 11/01/2022 88020 Work Orders WO#: 13579245

/ C270P008 Level Detect LIT 34701 11/01/2022 88020 Work Orders WO#: 13591215

/ C822I011 Thermocouple Calibration 02/04/2023 88020 Work Orders WO#: 13594750

/ C270I018 Flowmeter DIT-30701 03/16/2023 88020 Work Orders WO#: 13594865

/ S932I001 Pressure Switch 03/24/2023 88020 Work Orders WO#: 13594866

/ S932I003 Pressure Switch 03/24/2023 88020 Work Orders WO#: 13594868

/ S932I004 Pressure Switch 03/24/2023 88020 Work Orders WO#: 13598962

/ C820P009 Discharge Interlock Line 1 04/05/2023 88020 Work Orders WO#: 13598963

/ C820P010 Discharge Interlock Line 1 04/05/2023 88020 Work Orders WO#: 13598966

/ C830P001 Powder Prep Interlocks 04/10/2023

19 Inspection Procedure Type Designation Description or Title Revision or Date 88020 Work Orders WO#: 13606408

/ C823I011 Thermocouple Calibration 06/09/2023 88020 Work Orders WO#: 13611775

/ C005P001 Cylinder recirculation sump pump and level 07/25/2023 88020 Work Orders WO#: 13619040 DOS Test 08/16/023 88020 Work Orders WO#: 13619285

/ C270I018 Flowmeter DIT-30701 09/15/2023 88020 Work Orders WO#: 13624787

/ C830P004 Powder Prep Discharge Interlocks 10/09/2023 88020 Work Orders WO#: 13624827

/ C820I016 Hygrometer L1 10/07/2023 88020 Work Orders WO#: 13624829

/ C821I011 Thermocouple Calibration 10/13/2023 88020 Work Orders WO#: 13624846

/ C830I005 Scale AZB 10/12/2023 88070 Corrective Action Documents CR-2022-3152 NCS Infraction 2022-031 - Calibration C270I006, Out of Tolerance, pH monitor reading low. - IROFS 232 degraded 12/07/2022 88070 Corrective Action Documents CR-2023-2063 NCS Infraction 2023-011: Sand Filter U-monitor 680-1 OUT OF TOLERANCE, IROFS #2309.00 Degraded 09/12/2023 88070 Corrective Action Documents CR-2023-2132 NCS Infraction 2023-012: IROFS 232 Failed: Calibration C270I006, out of tolerance, PH was reading low, did a calibration and brought it back in, back in to service 09/20/2023 88070 Corrective Action Documents Resulting from Inspection CR-2023-2580 NRC Audit Inspection 2023-004: Nuclear Criticality Safety -

IP 88015; and Plant Modifications - IP88070 10/26/2023 88070 Drawings CSA-607590 Horn Rapids Rd Site General Arrangement Pellet Grinding &

Inspection System Revision 43 88070 Drawings CSA-611960 HRR Site Ventilation Duct System K3 Flow Diagram Revision 25 88070 Drawings CSA-617,136 BLEU Pelletizing Burnback/Oxidation Rotary Split Tube Furnace (sheets 1-8)

Revision 0 88070 Drawings CSA-617108-001 BLEU Calciner Vacuum Transfer Receiver Vessel Revision B 88070 Drawings CSA-618085 COE Grinder Sludge Station Revision 001 88070 Drawings DS-DH-19-000 Line 6 Calciner Seal Cover Upper Clam Shell Revision 0

20 Inspection Procedure Type Designation Description or Title Revision or Date 88070 Drawings DS-DH-19-001 Line 6 Calciner Seal Cover Lower Clam Shell Revision 0 88070 Engineering Changes E04-NCSA-960 HVAC Exhaust Systems Version 42.0 88070 Engineering Evaluations E04-NCSA-135 Line 6 Scrap Recovery Version 20.0 88070 Engineering Evaluations E04-NCSA-163 Industrial Waste Water Treatment Facilities Version 36.0 88070 Engineering Evaluations E04-NCSA-190 UO2 Pellet Dissolution Version 19.0 88070 Engineering Evaluations E04-NCSA-260 SURF Dissolution Version 7.0 88070 Engineering Evaluations E04-NCSA-270 SURF Solvent Extraction (SX) and Raffinate Treatment Version 5.0 88070 Engineering Evaluations E04-NCSA-360 Lube Blend Press Feed Version 19.0 88070 Engineering Evaluations E04-NCSA-390 UO2 Pellet Grinding & Inspection Version 24.0 88070 Miscellaneous Purchase Order - Replace the spargers on the ARF 780 IX Column 10/17/2023 88070 Miscellaneous Organizational Chart of the Plant Engineering, Technical Support, and Maintenance Division 88070 Miscellaneous HRR Site and Facilities Maintenance Plan of the Day October 24, 2023 88070 Miscellaneous ECN 8935 Package Line 6 Calciner Improvements 06/11/2020 88070 Miscellaneous ECN 8967 Package AFM Process Containers-45 Gallon Powder Drums 09/29/2022 88070 Miscellaneous ECN 8968 Package SURF Pellet Dissolver Modifications 08/19/2021 88070 Miscellaneous ECN 8973 Package UO2 Sludge Station Modification 01/28/2022 88070 Miscellaneous ECN 9015 Package ARF Assay Replacement Tanks 714, 717, 680, 780 10/28/2022 88070 Miscellaneous HRR-CRT-Training Curriculum - Integrated Safety Analysis (ISA) 06/30/2022

21 Inspection Procedure Type Designation Description or Title Revision or Date 800001-005 88070 Miscellaneous HRR-CRT-800001-006 Training Curriculum - Items Relied On For Safety 07/25/2022 88070 Miscellaneous HRR-CRT-800001-007 Training Curriculum - IROFS Database 06/29/2022 88070 Miscellaneous HRR-CRT-800001-008 Training Curriculum - Roles and Responsibilities 06/29/2022 88070 Miscellaneous HRR-CRT-800001-009 Training Curriculum - Going Forward 07/25/2022 88070 Procedures MCP-30140 Project Objectives Version 6.0 88070 Procedures MCP-30147 Startup Council Version 9.0 88070 Procedures MCP-30379 Construction or Modification Change Control Version 19.0 88070 Procedures MCP-30379 A Construction or Modification Change Control - Initiation Version 6.0 88070 Procedures MCP-30379 B Construction or Modification Change Control - Planning Version 4.0 88070 Procedures MCP-30379 C Construction or Modification Change Control - Execution Version 13.0 88070 Procedures MCP-30379 D Construction or Modification Change Control - Controlling Version 9.0 88070 Procedures MCP-30379 E Construction or Modification Change Control - Closure Version 5.0 88070 Procedures MCP-31210 Industrial Waste Water Treatment (System 163) Controls Design Description Version 5.0 88070 Procedures SOP-40256 ARF Ion Exchange System Version 19.0 88070 Procedures SOP-40258 Sand Filter and Ion Exchange Column Backwash Processing Version 10.0 88070 Procedures SOP-40791 Pre-Job Briefing Procedure Version 21.0 88070 Procedures SWI-40258 A Backwash Processing Version 10.0 88070 Self-Assessments MMD-21-003 Annual Configuration Control Audit Report - 2021 12/29/2021 88070 Self-Assessments SCP-23-001 Annual Configuration Control Audit Report - 2022 03/06/2023 88070 Work Orders 11550264 Pre work for assay rad detectors 04/08/2023 88070 Work Orders C162I102-0005 DETEC ASSY TK680-2 1 MO IN 07/05/2023 88070 Work Orders C163I102 DETEC ASSY TK780-1 1 MO IN 09/11/2023 88070 Work Orders C163I102-0001 Detec Assay Tk714 (monthly)

April -

September, 2023 88070 Work Orders C163I102-0002 Detec Assay Tk714 (monthly)

April -

September

22 Inspection Procedure Type Designation Description or Title Revision or Date 2023 88070 Work Orders C163I102-0002 DETEC ASSAY TK717 1 MO IN 09/12/2023 88070 Work Orders C163I102-0003 DETEC ASSY TK680-1 1 MO IN 08/11/2023 88070 Work Orders C163I102-0003 Detec Assay Tk714 (monthly)

April -

September 2023 88070 Work Orders C163I102-0004 Detec Assay Tk714 (monthly)

April -

September 2023 88070 Work Orders C163I102-0005 Detec Assay Tk714 (monthly)

April -

September 2023 88070 Work Orders C163I102-0006 Detec Assay Tk714 (monthly)

April -

September 2023 88070 Work Orders C163I102-0006 DETEC ASSY TK780-2 1 MO IN 08/04/2023 88070 Work Orders C163P104 IX Feed Interlock Checks (6 Mo) 07/01/2023 88070 Work Orders C260I003 Flowmeter DIT/FIT-33202 (6-month interval) 09/15/2023 88070 Work Orders C260P001 SURF Interlock Check (1-year interval) 12/01/2022