ML24190A029
| ML24190A029 | |
| Person / Time | |
|---|---|
| Site: | Framatome ANP Richland |
| Issue date: | 07/19/2024 |
| From: | Eric Michel NRC/RGN-II/DFFI |
| To: | Stephens L Framatome ANP Richland |
| References | |
| IR 2024002 | |
| Download: ML24190A029 (22) | |
Text
Lance Stephens Site Manager Framatome 2101 Horn Rapids Road Richland, WA 99354
SUBJECT:
FRAMATOME - CORE INSPECTION REPORT 07001257/2024002
Dear Lance Stephens:
On June 30, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Framatome. On May 16 and July 18, 2024, NRC inspectors 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, 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 19, 2024 Signed by Michel, Eric on 07/19/24
SUNSI Review X
Non-Sensitive
Sensitive X
Publicly Available
Non-Publicly Available OFFICE RII/DFFI RII/DFFI RII/DFFI RII/DFFI NAME T. Sippel G. Goff C. Taylor E. Michel DATE 07/08/24 07/09/24 07/15/24 07/19/24
Enclosure U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number:
07001257 License Number:
SNM-1227 Report Number:
07001257/2024002 Enterprise Identifier:
I-2024-002-0046 Licensee:
Framatome Facility:
Framatome Location:
Richland, WA Inspection Dates:
May 13, 2024 to May 17, 2024 Inspectors:
G. Goff, Fuel Facilities Inspector T. Sippel, Sr. Fuel Facility Projects 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, 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 07001257/2023-003-00 10 CFR 71.95 - 60 Day Report - 30B Cylinder Valve Installation 86740 Closed WER 07001257/2023-005-00 10 CFR 71.95 - 60 Day Report - TN-B1 Certificate Not Followed 86740 Closed URI 07001257/2024002-01 CAAS Coverage of Subsurface Areas 88015 Open URI 07001257/2022004-02 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 (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 program to verify compliance with selected portions of 10 CFR 70, including 70.24, 70.61, 70.62, and Appendix A, Chapter 5, Nuclear Criticality Safety, of the facilitys license application, and applicable licensee procedures.
Criticality Analysis (IP Section 02.01)
The inspectors interviewed licensee staff and reviewed nuclear criticality safety analyses (NCSAs) to verify compliance with 10 CFR 70 and applicable sections of the license application, including 5.3.1, 5.3.2, 5.3.4 and 5.4.2. Specifically, the inspectors interviewed licensee staff and reviewed the following:
E04-NCSA-260, "Scrap Uranium Recovery Facility (SURF) Dissolution,"
Version 8.0, including the review of accident sequences involving backflow, accumulations of uranium, spills of uranium, unfavorable geometries, and the basis for why the licensee screened certain accident sequences as not credible E04-NCSA-270, "SURF Solvent Extraction (SX) and Raffinate Treatment,"
Version 6.0, including the review of accident sequences involving transfers to unfavorable geometries, backflow, accumulations of uranium, and the basis for why the licensee screened certain accident sequences as not credible E04-NCSA-328, "DCF Scrap Download Hood Operations," Version 10.0, including the review of accident sequences involving the loading of drums, the introduction of moderator, and reviewing the basis for why the licensee screened certain accident sequences as not credible E04-NCSS-800, "General DCF Requirements," Version 20.0
4 E04-NCSS-G81, "45-Gallon Powder Drums with Neutron Absorbing Inserts,"
Version 26.0 E04-NCSS-G95, "Safe Batch Containers (SBCs) and other Miscellaneous Metal Containers Containing Uranium Compounds," Version 18.0, which was reviewed because this revision contained information on a new container flowdown of NCS controls from the above documents into implementing documents, as well as selected NCS models and calculations for normal and accident conditions and applicable increased enrichment analysis and calculations in the documents above, and supporting information for selected calculations and controls Criticality Implementation (IP Section 02.02)
The inspectors selected engineered and administrative items relied on for safety (IROFS) from the licensees integrated safety analysis (ISA) summary to verify proper implementation through a review of process and IROFS descriptions and documentation, plant walkdowns, and interviews with operators and engineers to verify compliance with 10 CFR 70 and applicable sections of the license application, including 5.3.1, 5.3.3 and 11.2. Specifically, the inspectors interviewed licensee staff, observed licensee activities and walked down equipment, and reviewed the following controls, and selected management measures, associated with the NCSAs listed above:
Passive Engineered Controls (PECs), including:
IROFS 416 IROFS 415/418 IROFS 1410.40 IROFS 1410.41 IROFS 1502.00 Active Engineered Controls (AECs), including:
IROFS 121/121.10 IROFS 122/122.10 IROFS 130/130.10 IROFS 224/225/226 IROFS 404.10/404.20/404.30 Administrative Controls, including:
IROFS 133 IROFS 139 IROFS 234 IROFS 2106 IROFS 3503.10 IROFS 6108 IROFS 6508 the inspectors selected applicable management measures for these IROFS to review which included: procedures, NCS postings, calibration records, and functional test records
5 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, including 5.3.10, 11.3.1 and 11.5.1.
Specifically, the inspectors performed the following activities:
observed a licensee NCS engineer conduct portions of the monthly audit in the field interviewed NCS staff about audits and the audit schedule, reviewed the monthly NCS audit schedule for 2024, and recent monthly NCS audit reports:
o E04-07-202311, "NCS Audit/Inspection Report - November 2023,"
Version 1.0 o
E04-07-202312, "NCS Audit/Inspection Report - December 2023,"
Version 1.0 o
E04-07-202401, "NCS Audit/Inspection Report - January 2024,"
Version 1.0 o
E04-07-202402, "NCS Audit/Inspection Report - February 2024,"
Version 1.0 o
E04-07-202403, "NCS Audit/Inspection Report - March 2024," Version 1.0 interviewed SURF operators and NCS engineers concerning criticality hazards and control methods, including monitoring, and preventing accumulations interviewed the NCS manager about the NCS function's oversight of NCS training reviewed NCS training materials for site personnel:
o COURSE-HRR-IND-500001, "Site Access Refresher e-Learning -
Module 2 Emergency Response," dated August 26, 2022 o
COURSE-HRR-CRT-500002, "Initial Criticality Safety Training," dated October 17, 2022 o
COURSE-HRR-CRT-500003, "Crit Safety Worker Refresher eLearning," dated November 18, 2022 o
COURSE-HRR-CRT-500004, "Crit Safety for Managers, Supervisors, and Engineers," dated December 8, 2022 Criticality Programmatic Oversight (IP Section 02.04)
The inspectors reviewed NCS program procedure revisions, recent plant changes, and NCS staff qualifications to verify compliance with 10 CFR 70 and applicable sections of the license application, including 5.2, 5.3.5, 5.3.6, and 5.3.7. Specifically, the inspectors interviewed licensee NCS staff and performed the following:
walked down new equipment (e.g., additional absorber IROFS in SURF, new drums) and discussed upcoming equipment changes (e.g., to smaller geometries and volumes) that supports sitewide increased enrichment activities interviewed the NCS manager about NCS review of changes as part of the change process
6 reviewed the most recent revision to licensee procedure E04-05-01, "Nuclear Criticality Safety Standards," Version 20.0, which included procedural requirements for NCS review of equipment changes, NCS Postings, NCS Training, etc.
reviewed E04-06-004, "Preparation & Review of Nuclear Criticality Safety Documents," Version 15.0 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, including 5.3.9, 5.3.10, 5.3.11, and 5.5. Specifically, the inspectors reviewed documents and interviewed licensee staff concerning:
a sample of recent NCS-related CAP entries, NCS Infractions, and associated documentation how the CAAS detector placement calculations (E04-09-001) cover large tanks and subsurface areas, including through walkdowns of selected subsurface locations drill records and resulting corrective actions for the most recent CAAS evacuation drill (e.g., JMD:23:018, CR-2023-2454)
Work Orders (WOs) and preventative maintenance (PM) procedures for the CAAS (e.g., WO 13587257, WO 13611517) emergency management procedures used for a CAAS evacuation (e.g., E08-03-8.13, "Criticality Alarm for PED")
training on CAAS evacuations (e.g., COURSE-HRR-IND-500001)
RADIOLOGICAL CONTROLS 86740 - Inspection of Transportation Activities The inspectors evaluated select aspects of the licensees Transportation Activities program to determine whether the licensee has established and is maintaining an effective, management-controlled program; to ensure radiological and nuclear safety in the receipt, packaging, delivery to a carrier and, as applicable, the private carriage of licensed radioactive materials; and to determine whether transportation activities are in compliance with the applicable NRC 10 CFR Parts 20 and 71 regulations and Department of Transportation (DOT) 49 CFR Parts 171-178 transport regulations, as applicable.
Preparation of Packages for Shipment (IP Section 02.01)
The inspectors examined the licensees procedures and shipment records and observed actual package preparations and operations to verify compliance with the regulations above. Specifically, the inspectors performed the following:
observed radiation and contamination surveys on:
o an outbound shipment of UX-30 overpacks containing 30B empty and heeled cylinders
7 o
an inbound shipment of 30B heeled cylinders o
an outbound shipment of MAP-12 fuel overpacks containing fuel rods observed tamper indicating devices (seals) were in the proper locations and intact on overpacks observed labeling, markings, and placarding of the containers and/or truck beds reviewed procedures:
o Standard Operating Procedure (SOP)-40181, Shipping, Receiving, &
Storage Operations, Version 8.0 o
SOP-40315, Recertification Testing and Inspection of UF6 Cylinders, Version 27.0 o
SOP-40319, General Packaging, Shipping and Receiving UF6 Cylinders and Protective Overpacks, Version 13.0 o
SOP-40525, Refurbishment of TN-B1 Shipping Containers and the Shipping and Receiving of UO2 Fuel Assemblies and Fuel Rods in TN-B1 Shipping Containers, Version 15.0 o
SOP-40932, Visual Inspection of UX-30 Welds, Version 5.0 o
SOP-40937, Shipping and Receiving of MAP-12/MAP-13 Shipping Containers, Version 11.0 reviewed standard work instructions (SWIs) and forms affiliated with the above procedures (see "Documents Section")
reviewed shipment records:
o MAP-12 Shipment, Shipment of Fuel Rods/Assemblies, dated April 10, 2024 o
TN-B1 Fuel Rod/Assembly, Shipment of Fuel Rods/Assemblies Package, dated February 16, 2024 o
UX-30 UF6-2024-24, Shipment of UX-30 Overpacks Package, dated April 15, 2024 Delivery of Completed Packages to Carriers (IP Section 02.02)
The inspectors examined the licensees procedures and shipment records and observed activities to determine that the licensee met package delivery requirements. Specifically, the inspectors performed the following:
reviewed SOP-40319, General Packaging, Shipping and Receiving UF6 Cylinders and Protective Overpacks, Version 13.0 reviewed the bill of lading and shipping manifest for an offsite shipment of UX-30 overpacks containing empty 30B cylinders to verify required information such as gross weight, size, shipper information, consignee information, radioactivity level, container identification, etc., was included observed the placarding, signage, labeling of the flat bed and 30B heeled cylinders interviewed the licensee regarding the shipment above regarding compliance with 10 CFR 71 and 49 CFR 172-178 requirements
8 Receipt of Packages (IP Section 02.03)
The inspectors examined the licensees procedure for an incoming shipment to verify compliance with 10 CFR 20.1906 and applicable license requirements. Specifically, the inspectors performed the following:
observed receipt of UX-30 (with heeled 30B cylinders) to include:
o radiation surveys (survey meter within calibration) o contamination surveys (analyzer within calibration) o unloading and storage of the 30B cylinders o
labeling of the packages o
placement of the 30B cylinders on the saddles in the cylinder yard o
position of valves at the 12 o'clock position reviewed SOP-40319, General Packaging, Shipping and Receiving UF6 Cylinders and Protective Overpacks, Version 13.0, and the following supporting documents:
o SWI-40319 A, Receiving Cylinder Overpacks, Weighing and Assaying of UF6 Cylinders, Version 19.0, o
SWI-40319 C, Shipping UF6 Cylinders and Protective Overpacks, Version 10.0, o
SWI-40319 D, Loading UF6 Cylinders into Protective Overpacks, Version 9.0, and shipment manifest, including the bill of lading Records and Reports (IP Section 02.04)
The inspectors examined the licensees records and reports to verify compliance with the regulations above. Specifically, the inspectors performed the following:
reviewed the following Safety Analysis Reports (SARs) for the following packages:
o SAR for Model UX-30 Package, Revision 4 o
Framatome TN-B1 Docket No. 71-9372 SAR, Revision 10.0 o
MAP PWR Fuel Shipping Package - USA/9319/B(U)F-96, Revision 5.0 reviewed the shipment records for the following:
o MAP-12 Shipment, Shipment of Fuel Rods/Assemblies, dated April 10, 2024 o
TN-B1 Fuel Rod/Assembly, Shipment of Fuel Rods/Assemblies Package, dated February 16, 2024 o
UX-30 UF6-2024-24, Shipment of UX-30 Overpacks Package, dated April 15, 2024 General License Requirements (IP Section 02.05)
The inspectors reviewed the certificate of compliance (CoC) utilized for shipment of radioactive material packages to verify compliance with 10 CFR 71, Subpart C. Specifically, the inspectors reviewed:
CoC 9196 for UX-30 packages (30B cylinders)
9 CoC 9372 for TN-B1 packages CoC 9319 for MAP-12 and MAP-13 packages CoC equivalent for Mitsubishi Fuel Corporation (MFC) packages Management Controls (IP Section 02.06)
The inspectors reviewed the system of management controls for transportation activities to verify compliance with licensee instructions and procedures. Specifically, the inspectors performed the following:
reviewed maintenance work orders for the past 12 months for the high purity germanium counters (used for determining enrichment level) for 30B cylinders (see the "Documents" section) reviewed calibration labels for the radiation survey meter and contamination analyzer for incoming and outgoing shipments reviewed the following shipment packages for required activities, reviews, and signature approvals from management and other required personnel:
o MAP-12 Shipment, Shipment of Fuel Rods/Assemblies, dated April 10, 2024 o
TN-B1 Fuel Rod/Assembly, Shipment of Fuel Rods/Assemblies Package, dated February 16, 2024 o
UX-30 UF6-2024-24, Shipment of UX-30 Overpacks Package, dated April 15, 2024 interviewed licensee management personnel on the three shipment packages above Indoctrination and Training Program (IP Section 02.07)
The inspectors conducted interviews and reviewed training curriculums and records for workers involved in transport activities to verify compliance with Chapter 11 of the licensee application. Specifically, the inspectors performed the following:
reviewed and compared the training curriculum and records for handlers of incoming and outgoing shipments interviewed the training manager regarding the initial and refresher training requirements for shipment workers interviewed workers in the transportation department regarding their training and their comfort level for raising safety concerns to management Quality Assurance Program (IP Section 02.08)
The inspectors reviewed the quality assurance documents to verify compliance with the licensees quality assurance (QA) program. Specifically, the inspectors reviewed:
SOP-40315, Recertification Testing and Inspection of UF6 Cylinders, Version 27.0 SOP-40932, Visual Inspection of UX-30 Welds, Version 5.0 SWI 40525 A, TN-B1 Outer Container Inspection - Station #1, Version 13.0
10 SWI 40525 C, Station #2 Inner Container Inspections - TN-B1 Containers, Version 13.0 SWI 50072 E, MAP 12 and 13 Shipping Container - Container Cleaning, Inspection and Up-Ending, Version 11.0 Audit Program (IP Section 02.09)
The inspectors reviewed the latest audits to verify compliance with 10 CFR 71.137. Specifically, the inspectors reviewed:
2023 SH-2 Licensed Packaging Audit Report, dated January 5, 2024 2nd 2023 SH-1 Regulated Shipment Biannual Audit, dated February 29, 2024 US Fuel Internal Audit Report, dated September 19-30, 2022 Procurement and Selection of Packagings (IP Section 02.10)
The inspectors examined the licensees packages and revised drawings and shipment records to verify compliance with the federal regulations above. Specifically, the inspectors performed the following:
reviewed drawings for the erroneous and corrected TN-B1 inner container (distance between pitch welds) reviewed drawings for UX-30 overpacks, 30B cylinders, MAP-12, and MAP-13 observed the inner container of a TN-B1 package and measured the distance between pitch welds in order to verify compliance with the CoC and the most recent drawing walked down and observed the following packages:
o TN-B1 overpacks o
MAP-12 overpacks o
MAP-13 overpacks o
MFC overpacks o
UX-30 overpacks o
30B cylinders Preparation of Packages for Shipment (IP Section 02.11)
The inspectors examined the licensees package condition, markings, labeling, and documentation to verify compliance with applicable parts of the federal regulations above. Specifically, the inspectors performed the following:
observed that the structural integrity on an outgoing shipment of empty and heeled 30B cylinders had no damage such as punctures, holes, intense corrosion, dents, etc.
observed that the structural integrity on an outgoing shipment of MAP-13 packages had no damage such as punctures, holes, intense corrosion, dents, etc.
observed packages for proper labeling and marking and the truck bed for proper placarding and signage
11 reviewed the shipment package which contained the advanced notification to consignees and the advanced notification to the state's governor Periodic Maintenance of Packagings (IP Section 02.12)
The inspectors examined the licensees procedures to verify compliance with applicable parts of the federal regulations above. Specifically, the inspectors observed the following:
a TN-B1 inner container refurbishment with the required padding, cushioning, linings, braces, bolts, and other stabilizing components and that these materials were in the proper arrangement according to the latest drawing (FS1-0042705, Revision 2) with no visible damage Records, Reports, and Notifications (IP Section 02.13)
The inspectors reviewed the licensees records to verify a system is in place to verify compliance with the federal regulations above. In addition, inspectors reviewed two written event reports (WERs) related to packages and shipping containers. Specifically, the inspectors reviewed the following:
reviewed shipment records:
o MAP-12 Shipment, Shipment of Fuel Rods/Assemblies, 4/10/2024 o
TN-B1 Fuel Rod/Assembly, Shipment of Fuel Rods/Assemblies Package, dated February 16, 2024 o
UX-30 UF6-2024-24, Shipment of UX-30 Overpacks Package, dated April 15, 2024 reviewed corrective actions for WER 07001257/2023-003 10 CFR 71.95 -
60 Day Report - 30B Cylinder Valve Installation (see Inspection Results Section) reviewed corrective actions for WER 07001257/2023-005 10 CFR 71.95 -
60 Day Report - TN-B1 Certificate Not Followed (see Inspection Results Section)
INSPECTION RESULTS WER (Closed) 10 CFR 71.95 - 60 Day Report - 30B Cylinder Valve Installation WER 07001257/2023-003-00 86740
==
Description:==
The inspectors reviewed the licensee's response to a 71.95 report sent to the NRC on October 16, 2023, and its corresponding 60-day follow-up event report (ADAMS ML23341A154) summited to the NRC on December 7, 2023. The issue involved a licensee identified failure to comply with 10 CFR 71.111, Instructions, Procedures, and Drawings, which requires licensees to follow procedures established for each CoC used by the licensee.
Specifically, the licensee failed to follow the procedure for torquing cylinder valves on 30B cylinders. The inspectors reviewed documents, interviewed personnel, and conducted plant walk-downs to assess the licensee's actions to determine whether violations of NRC requirements occurred. The inspectors identified a minor violation (see "Minor Violation" section of this inspection report for details). WER 07001257/2023-003-00 is considered closed to a minor violation.
12 Minor Violation 86740 Minor Violation - Exceeding Torque Limits for 30B Cylinder Valves
==
Description:==
On October 16, 2023, a recertification technician incorrectly used a torque wrench on the 30B cylinder valve in such a way that it may have exceeded the 400 ft-lbf safety limit per the American National Standards Institute (ANSI) N14.1, "Uranium Hexafluoride Packagings Transport," (CoC 9196) as well as the procedural limit of 384 ft-lbf identified in licensees procedure SWI-40315 C, "Installing Valves and Plugs and Leak Testing, Version 16.
Screening: Inspectors determined that a minor violation of 10 CFR 71.111, Instructions, Procedures, and Drawings, occurred which requires that licensees follow their established procedures for CoCs. Specifically, the licensees procedure, SWI-40315 C, "Installing Valves and Plugs and Leak Testing, Version 16, Section 1h requires cylinder valves be torqued to no more than 384 ft-lbf.
Contrary to the above, the licensee failed to torque 30B cylinder valves to no more than the maximum torque limit of 384 ft-lbf because the procedure step was vague. This issue had been ongoing since August 2023. Upon discovery of the issue, the licensee immediately stopped unsupervised cylinder valve installation activities. As part of the corrective actions, inspectors reviewed (1) the latest revision to procedure SWI-40315 C, Version 20, that provided additional guidance on the installation and torquing of valves in accordance with ANSI N14.1 and (2) additional training for technicians on the procedural changes and proper torque wrench operation. The issue was entered into the licensees corrective action program as Condition Report (CR) 2023-2443.
The inspectors determined the violation was minor and aligned most closely with Example 5g using the screening criteria in Appendix B, Examples of Minor Violations in Inspection Manual Chapter (IMC) 0616, Fuel Cycle Safety and Safeguards Inspection Reports. The issue was minor because the affected 30B cylinders left the site hydrostatically leak tested and empty. In addition, no domestic or foreign customer, who received the affected 30B cylinders, reported any concerns with cylinder valve performance or integrity. In addition, this minor violation resulted in no actual safety consequences.
Enforcement: The failure to comply with 10 CFR 71.111 constitutes a minor violation that is not subject to enforcement action in accordance with Section 2.3.1 of the NRCs Enforcement Policy and this issue is considered closed with no further action needed.
WER (Closed) 10 CFR 71.95 - 60 Day Report - TN-B1 Certificate Not Followed WER 07001257/2023-005-00 86740
==
Description:==
The inspectors reviewed the licensee's response to a 71.95 report sent to the NRC on September 27, 2023, and its corresponding 60-day follow-up event report (ADAMS ML23282A008) sent to the NRC on October 9, 2023. The issue involved a licensee identified typographical drawing (dwg) error between a TN-B1 dwg, FS1-0042705, Rev. 1 and the original vendor drawing,105E3745, Rev. 8. The typographical dwg error decreased the distance between plug pitch welds from 600 millimeters (mm) to 200 mm thereby increasing the number of plug pitch welds required on the inner container of the TN-B1 transport package to a value greater than the number of plug pitch welds made on all as-built TN-B1 inner containers.
13 The inspectors reviewed the corrected TN-B1 dwg, FS1-0042075, Rev. 2 and the current CoC 9372, dwg 105E3745, Rev. 8. The inspectors confirmed both documents displayed the same plug pitch weld dimensions. The inspectors used a measuring tape to verify the applicable dimensions in the corrected dwg matched the as-found dimensions of the TN-B1 transport package inner container. Because this was an administrative, typographical error and the physical distance between plug pitch welds was unaltered, there was no actual safety consequence, and no violations of NRC requirements were identified. WER 07001257/2023-005-00, "10 CFR 71.95 - 60 Day Report - TN-B1 Certificate Not Followed," is considered closed with no further action needed.
Unresolved Item (Open)
CAAS Coverage of Subsurface Areas URI 07001257/2024002-01 88015
==
Description:==
The inspectors walked down the location of selected subsurface areas (e.g.,
pits, below grade tanks), and interviewed licensee NCS engineers about the processes and accident sequences in those areas. The inspectors walked down nearby CAAS detectors, reviewed portions of E04-09-001, "HRR Criticality Accident Alarm System Coverage Demonstration," and interviewed NCS engineers about the design of the CAAS and the detector placement calculations, including the conservatism in those calculations.
However, it was not clear that the CAAS would be able to detect a criticality located in those locations as required by 10 CFR 70.24. The inspectors noted in all these locations there were no credible criticality accident sequences in the subsurface areas. Therefore, the inspectors did not identify any immediate safety concerns.
Planned Closure Actions: The inspectors will review updated licensee detector placement calculations to verify that the CAAS can detect a criticality located in subsurface areas. These areas include, but are not necessarily limited to, the retention tank(s) near the UO2 Building, the inspection 'pit' in the UO2 Building, and Tank-949 in the UO2 Building.
Licensee Actions: Perform more detailed updated calculations and determination of CAAS coverage as described above.
Corrective Action
References:
The licensee opened CR-2024-1303 to document this issue and to track it to resolution.
EXIT MEETINGS AND DEBRIEFS The inspectors verified no proprietary information was retained or documented in this report.
On May 16 and July 18, 2024, the inspectors presented the nuclear criticality safety and transportation inspection results to Lance Stevens and other members of the licensee staff.
14 DOCUMENTS REVIEWED Inspection Procedure Type Designation Description or Title Revision or Date 86740 Corrective Action Documents CR-2021-1924 SP-1 Dent 08/23/2021 86740 Corrective Action Documents CR-2022-2246 TN-B1 Bolt Holder 09/15/2022 86740 Corrective Action Documents CR-2023-2220 TN-B1 Plug Weld Pitch 09/27/2023 86740 Corrective Action Documents CR-2023-2443 30B Valve Torque 10/16/2023 86740 Corrective Action Documents CR-2023-2899 NMS&R-Failed Sorbothane bushings found in TN-B1 Shipping Containers 11/22/2023 86740 Drawings List of Changes to FS1-0042705 Revision 2 86740 Drawings FS1-0042705 (related to FS1-
- 0014159, Revision 10.0)
TN-B1 Inner Container Main Body Assembly Licensing Drawing Revisions 1 and 2 86740 Engineering Evaluations Safety Analysis Report for Model UX-30 Package Revision 4 86740 Engineering Evaluations E04-NCSA--000 Nuclear Criticality Safety Specifications & Non-Criticality Safety IROFS Version 11.0 86740 Engineering Evaluations E04-NCSA-761 Between Building Transfer Version 27.0 86740 Engineering Evaluations FS1-0014159 Framatome TN-B1 Docket No. 71-9372 Safety Analysis Report Revision 10.0 86740 Engineering Evaluations FS1-0038397 MAP PWR Fuel Shipping Package - USA/9319/B(U)F-96 (SAR)
Revision 5.0 86740 Miscellaneous HRR Site and Facilities Maintenance Plan of the Day Agenda May 13, 2024 86740 Miscellaneous E17-05-025 Shipping Compliance Checklist Revision 17.0 86740 Miscellaneous Form 20174 30B UF6 Cylinder Recertification Record Follower Card (March, June, August, & September 2023)
Version 16.0 86740 Miscellaneous FRM-40045-A Release, Shipping, & Receiving Version 6.0
15 Inspection Procedure Type Designation Description or Title Revision or Date 86740 Miscellaneous FS1-0038397 MAP PWR Fuel Shipping Package - USA/9319/B(U)F-96 Revision 5.0 86740 Miscellaneous NCSP-000-002 UF 6 Cylinder Storage Version 1.1 86740 Miscellaneous NRC Form 618 Certificate of Compliance 9319 (MAP-12 & MAP-13 packages)
Revision 14.0 86740 Miscellaneous NRC Form 618 Certificate of Compliance 9196 (UX-30 package)
Revision 31 86740 Miscellaneous NRC Form 618 Certificate of Compliance 9372 (TN-B1 package)
Revision 4 86740 Procedures 1703-89 US Fuel Condition Report and Suggestion for Improvement Screening Process Revision 002 86740 Procedures FRM-20413 TN-B1 Outer Shipping Container Re-Use Conformance Report Version 14.0 86740 Procedures FRM-20414 TN-B1 Inner Shipping Container RE-Use Conformance Report Version 11.0 86740 Procedures FRM-20457 MAP-12/MAP-13 Container Shipment Release Version 5.0 86740 Procedures FRM-20532 MAP-12/MAP-13 Shipping Container Re-Use Conformance Report Version 10.0 86740 Procedures FRM-20590 TN-B1 Container Shipment Release Version 3.0 86740 Procedures SOP-40181 Shipping, Receiving, & Storage Operations Version 8.0 86740 Procedures SOP-40315 Recertification Testing and Inspection of UF6 Cylinders Version 27.0 86740 Procedures SOP-40319 General Packaging, Shipping and Receiving UF6 Cylinders and Protective Overpacks Version 13.0 86740 Procedures SOP-40525 Refurbishment of TN-B1 Shipping Containers and the Shipping and Receiving of UO 2 Fuel Assemblies and Fuel Rods in TN-B1 Shipping Containers Version 15.0 86740 Procedures SOP-40932 Visual Inspection of UX-30 Welds Version 5.0 86740 Procedures SOP-40937 Shipping and Receiving of MAP-12/MAP-13 Shipping Containers Version 11.0 86740 Procedures SWI-40315 C Installing Valves and Plugs and Leak Testing Versions 16.0 - 20.0 86740 Procedures SWI-40319 A Receiving Cylinder Overpacks, Weighing and Assaying of UF6 Cylinders Version 19.0 86740 Procedures SWI-40319 C Shipping UF6 Cylinders and Protective Overpacks Version 10.0 86740 Procedures SWI-40319 D Loading UF6 Cylinders into Protective Overpacks Version 9.0 86740 Procedures SWI-40409 C TN-B1 Shipping Container Packing and Unpacking Version 32.0 86740 Procedures SWI-40409 E Replacing Heliserts -TN-B1 Containers Version 4.0
16 Inspection Procedure Type Designation Description or Title Revision or Date 86740 Procedures SWI-40525 A TN-B1 Outer Container Inspection - Station #1 Version 13.0 86740 Procedures SWI-40525 C Station #2 Inner Container Inspections - TN-B1 Containers Version 13.0 86740 Procedures SWI-40525 F Station #3 Inner/Outer Container Verifications - TN-B1 Containers Version 11.0 86740 Procedures SWI-50072 B MAP 12 and 13 Shipping Container Packing Fuel Assemblies Version 24.0 86740 Procedures SWI-50072 E MAP 12 and 13 Shipping Container - Container Cleaning, Inspection and Up-Ending Version 11.0 86740 Procedures SWI-50211 A Preparation of MAP-12/MAP-13 Containers Version 12.0 86740 Procedures SWI-50211 B MAP-12/MAP-13 Container Gasket Replacement Version 4.0 86740 Procedures SWI-50254 A Packing BWR Rods in a TN-B1 Container Version 9.0 86740 Radiation Surveys VSDS One Liner Survey Report (incoming shipment of UF6 heel cylinders).
05/15/2024 86740 Radiation Surveys VSDS One Liner Survey Report (staging of MAP-13 containers with fuel assemblies) 05/16/2024 86740 Radiation Surveys VSDS One Liner Survey Report (outgoing shipment of heeled 30B cylinders in UX-30 overpacks).
05/13/2024 86740 Self-Assessments 2023 SH-2 Licensed Packaging Audit Report 01/05/2024 86740 Self-Assessments 2nd 2023 SH-1 Regulated Shipment Biannual Audit 02/29/2024 86740 Self-Assessments 22:71 Internal Audit Report - US Fuel - 10 CFR 71, Subpart H Compliance Sept. 19, 2022 - Sept.
30, 2022 86740 Shipping Records MAP-12 Shipment Shipment of Fuel Rods/Assemblies 4/10/2024 86740 Shipping Records TN-B1 Fuel Rod/Assembly Shipment of Fuel Rods/Assemblies Package 02/16/2024 86740 Shipping Records UX-30 UF6-2024-24 Shipment of UX-30 Overpacks Package 04/15/2024 86740 Work Orders WO#: 13587642 C000I002 ASSAY UF6 CYLINDER (WEST) 01/05/2023 86740 Work Orders WO#: 13598396 C000I003 ASSAY UF6 CYLINDER (EAST) 04/01/2023 86740 Work Orders WO#: 13602441 C000I003 ASSAY UF6 CYLINDER (EAST) 05/01/2023 86740 Work Orders WO#: 13605794 C000I003 ASSAY UF6 CYLINDER (EAST) 06/01/2023 86740 Work Orders WO#: 13611352 C000I003 ASSAY UF6 CYLINDER (EAST) 07/01/2023 86740 Work Orders WO#: 13615993 C000I003 ASSAY UF6 CYLINDER (EAST) 08/01/2023
17 Inspection Procedure Type Designation Description or Title Revision or Date 86740 Work Orders WO#: 13619041 C000I003 ASSAY UF6 CYLINDER (EAST) 09/01/2023 86740 Work Orders WO#: 13624148 C000I003 ASSAY UF6 CYLINDER (EAST) 10/01/2023 86740 Work Orders WO#: 13627755 C000I003 ASSAY UF6 CYLINDER (EAST) 11/01/2023 86740 Work Orders WO#: 13632286 C000I003 ASSAY UF6 CYLINDER (EAST) 12/01/2023 86740 Work Orders WO#: 13636414 C000I003 ASSAY UF6 CYLINDER (EAST) 01/01/2024 86740 Work Orders WO#: 13640053 C000I003 ASSAY UF6 CYLINDER (EAST) 02/01/2024 86740 Work Orders WO#: 13643760 C000I003 ASSAY UF6 CYLINDER (EAST) 03/01/2024 86740 Work Orders WO#: 13649879 C000I003 ASSAY UF6 CYLINDER (EAST) 04/04/2024 88015 Corrective Action Documents CR-2023-2454, CR-2023-2663, CR-2023-2870, CR-2023-3107, CR-2024-0008, CR-2024-0131, CR-2024-0386, CR-2024-0992, CR-2024-1042, CR-2024-1296 NCS-related CAP Entries Various 88015 Corrective Action Documents NCS Infraction 23-015,23-016, 24-001,24-002, 24-003,24-004 NCS Infractions Various 88015 Corrective Action Documents Resulting from Inspection CR-2024-1303 88015 Drawings CSA-611620 Sheet 003 Scrap UN Recovery Facility... Process and Inst Diagram, showing IROFS 130 sensors Rev. 0 88015 Drawings CSA-618100-087 Rev. 0 88015 Drawings CSA-618100-088 Rev. -.A 88015 Engineering Evaluations E04-09-001 HRR Criticality Accident Alarm System Coverage Demonstration Version 8.0 88015 Engineering Evaluations E15-01-2.10 Dry Conversion Facility Version 21.0
18 Inspection Procedure Type Designation Description or Title Revision or Date 88015 Engineering Evaluations E15-01-2.22 Scrap Uranium Recovery Facility (SURF)
Version 5.0 88015 Miscellaneous JMD:23:016 Criticality Evacuation Exercise - 4th Quarter 2023 09/27/2023 88015 Miscellaneous JMD:23:018 After Action Report for Semi-Annual Criticality Evacuation Exercise on October 12, 2023 11/16/2023 88015 Procedures C080I003 Monitor Uranium UO2 1 Mo IN Version 7.0 88015 Procedures E04-06-004 Preparation & Review of Nuclear Criticality Safety Documents Version 15.0 88015 Procedures E08-03-8.13 Criticality Alarm for PED Version 5.0 88015 Procedures E08-03-8.13A Criticality Alarm for IPED, on Backshifts, Weekends, Holidays Version 3.0 88015 Procedures E08-03-8.13B Criticality Alarm for IC Version 2.0 88015 Procedures MCP-30340 Essential Material Class I: 45-Gallon Powder Containers with Neutron Absorber Inserts Version 9.0 88015 Procedures MCP-30597 Essential Material Class I: Five Gallon Metal Pails (SBC)
Version 4.0 88015 Procedures MCP-31446 Essential Material Class I: 2.5-Gallon Metal Pails (SBC)
Version 1.0 88015 Procedures PM005489 Criticality Audible Volume Check 5Yr EL Rev. 1 88015 Procedures PM005495 Criticality Howlers 6 Mo EL Rev. 4 88015 Procedures SOP-40251 Removing and Returning Poisoned 45-Gallon Drums into Service Version 13.0 88015 Procedures SOP-41140 SURF Pellet Dissolver Version 3.0 88015 Procedures SOP-41141 SURF Scrap Powder Dissolution Version 8.0 88015 Procedures SOP-41142 SURF Filtration Version 6.0 88015 Procedures SOP-41144 SURF Raffinate Processing Version 5.0 88015 Work Orders 13571483 C260P003 SURP PWDR DISS FLTR Boron 2Y RE Completed 09/26/2022 88015 Work Orders 13587257 PM005489 CRIT AUDIBLE VOL CHK 5YR EL Completed 02/07/2023 88015 Work Orders 13611517 PM005495 CRITICALITY HOWLRS 6 MO EL Completed 08/10/2023 88015 Work Orders 13627910 C270I013 XMITER LIT-318A1 6 MO IN Completed 11/04/2023 88015 Work Orders 13627917 C270I012 XMITER LIT-317A1 6 MO IN Completed 11/04/2023
19 Inspection Procedure Type Designation Description or Title Revision or Date 88015 Work Orders 13627934 C260P001 SURF Interlock Check 1 Yr IN Completed 11/22/2023 88015 Work Orders 13627935 C270P001 SURF Interlock Check 1 Yr IN Completed 11/30/2023 88015 Work Orders 13636627 C270I011 PRESSURE XMTR LIT-304A1 6 MO IN Completed 01/16/2024 88015 Work Orders 13643957 C270I004 FLOWMETER DIT-31002 6 MO IN Completed 03/07/2024 88015 Work Orders 13643960 C270I003 FLOWMETER DIT-30902 6 MO IN Completed 03/05/2024 88015 Work Orders 13644023 C260I003 Flowmeter DIT/FIT-33202 6 Mo IN Completed 04/25/2024 88015 Work Orders 13650072 C270I001-0001 ASSAY DETECTOR 1 MO IN Completed 04/03/2024