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Framatome - Core Inspection Report 07001257/2024004
	ML25016A058
Person / Time
Site:	Framatome ANP Richland
Issue date:	01/21/2025
From:	Eric Michel; NRC/RGN-II/DFRSS
To:	Stephens L; Framatome
References
	IR 2024004
	Download: ML25016A058 (17)
	v • d • e

Lance Stephens Site Manager Framatome 2101 Horn Rapids Road Richland, WA 99354

SUBJECT:

FRAMATOME - CORE INSPECTION REPORT 07001257/2024004

Dear Lance Stephens:

This letter refers to the Nuclear Regulatory Commission (NRC) inspection activities conducted from October 1 to December 31, 2024, for the Framatome facility. On November 22, 2024, the NRC completed an inspection at Framatome and discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.

No violations of more than minor significance were identified during this inspection.

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Eric C. Michel, Chief Fuels Oversight Branch 2 Division of Fuels, Radiological Safety, and Security Docket No. 07001257 License No. SNM-1227

Enclosure:

As stated cc w/ encl: Distribution via LISTSERV January 21, 2025 Signed by Michel, Eric on 01/21/25

ML25016A058 X

SUNSI Review X

Non-Sensitive

Sensitive X

Publicly Available

Non-Publicly Available OFFICE RII/DFRSS RII/DFRSS RII/DFRSS NAME K. Sullivan C. Taylor E. Michel DATE 1/16/25 1/21/25 1/21/25

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

07001257 License Number:

SNM-1227 Report Number:

07001257/2024004 Enterprise Identifier:

I-2024-004-0044 Licensee:

Framatome Facility:

Framatome Location:

Richland, WA Inspection Dates:

November 18, 2024 to November 22, 2024 Inspectors:

G. Goff, Fuel Facilities Inspector T. Sippel, Senior Fuel Facility Project Inspector Approved By:

Eric C. Michel, Chief Fuels Oversight Branch 2 Division of Fuels, Radiological Safety, and Security

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 Unresolved Issue (URI) 07001257/2024002-01 CAAS Coverage of Subsurface Areas 88015 Closed

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 Code of Federal Regulations (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), and associated documentation, to verify compliance with 10 CFR 70 and applicable sections of the license application, including 5.3.2, 5.3.4, 5.3.5, and 5.4.2.1.

Specifically, the inspectors interviewed licensee staff and reviewed the following NCSAs:

E04-NCSA-090, "UO2 Powder Production," Version 19.0, including the review of accident sequences 090-1.1, 1.2, 1.3, 2.1, 5.1, 5.2, 6.2, 6.4, 10.1, 10.2, and 10.3 which cover various process upsets resulting in moderated material in a drum and/or moderated material being spilled, as well as reviewing the licensee's basis for screening certain accident sequences (e.g. 8.1) as not credible E04-NCSA-550, "Bundle Disassembly," Version 9.0, including reviewing the new analysis of upset cases for 6.5% enriched bundles E04-NCSA-820, "Dry Conversion Powder Production Process," Version 21.0, including the review of accident sequences 820-1.1, 1.2 and 1.3 which cover various process upsets resulting in moderated material in reactors and calciners and maintaining reactor geometry E04-NCSA-080, "ADU Uranium Recovery," Version 27.0, including the review of accident sequences 080-1.1, 3.1, 3.2, 4.1, 4.18 which cover various process upsets resulting in accumulation of mass and geometry control, as

4 well as reviewing the licensee's basis for screening certain accident sequences (e.g. 080-3.8-3.16) as not credible XN-NF-83-45, "UF6 Dry Conversion Process Verification Tests," dated June 16,1983, which was reviewed because it contained information supporting the licensee's evaluation of criticality accident sequences and controls in E04-NCSA-820 reviewed the current validation reports for SCALE 6.2.2 Criticality Implementation (IP Section 02.02)

The inspectors selected engineered and administrative controls from the licensees integrated safety analysis (ISA) summary 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, including 5.3.6, 5.3.7, 5.4.2.3, 5.4.2.6, 5.4.2.10, and 5.4.2.14. Specifically, the inspectors interviewed licensee staff and reviewed the following controls, and selected management measures:

Passive Engineered Controls, including:

IROFS 1015, a geometry control IROFS 1020, a geometry control IROFS 1502, an absorber control IROFS 2224, a geometry control IROFS 3507.3, a geometry control IROFS 6206, a mass control Active Engineered Controls, including:

IROFS 1016, a moderator control IROFS 1208, a mass control IROFS 2204, a moderator control IROFS 2205, a moderator control IROFS 2206, a moderator control IROFS 2207, a moderator control IROFS 2209, a mass control IROFS 2211, a mass control IROFS 6213, a mass and geometry control Administrative Controls, including:

IROFS 2225, a mass control IROFS 3503, a geometry control the inspectors reviewed applicable management measures for the IROFS above such as postings in area, procedures, and maintenance and calibration records

5 Criticality Operational Oversight (IP Section 02.03)

The inspectors assessed the nuclear criticality safety (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, and 11.5.1. Specifically, the inspectors performed the following activities:

observed a licensee NCS engineer conduct portions of a monthly audit in the field, and interviewed licensee NCS engineers about the NCS audits reviewed the procedure for NCS audits (E04-06-002), the 2024 and 2025 NCS Audit Schedules and recent monthly audit reports:

o E04-07-202405, "NCS Audit/Inspection Report - May 2024," dated June 14, 2024 o

E04-07-202406, "NCS Audit/Inspection Report - June 2024," dated July 25, 2024 o

E04-07-202407, "NCS Audit/Inspection Report - July 2024," dated August 8, 2024 o

E04-07-202409, "NCS Audit/Inspection Report - September 2024,"

dated October 15, 2024 reviewed the Walkdown Logbook for 2024, the procedure for walkdowns (E04-06-007) and interviewed NCS engineers about walkdowns interviewed four area operators concerning criticality hazards and control methods for the calciners and dry conversion process 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, including 11.5.2. Specifically, the inspectors interviewed licensee NCS staff and reviewed the following documents:

NCS engineer qualification status documented for in-training NCS engineers and interviewed licensee NCS engineers the most recent external audit of the licensee's NCS program: FRA_D3SEP_IG_24-024_IR, "Nuclear Safety Criticality," dated June 18, 2024 the most recent revision to licensee procedure E04-06-004, "Preparation &

Review of Nuclear Criticality Safety Documents," Version 17.0

6 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 5.3.10 and 5.5. Additionally, the inspectors followed-up on an unresolved issue (URI) related to CAAS coverage of subsurface areas, which is documented below. Specifically, the inspectors reviewed and/or interviewed licensee staff concerning the following:

a sample of NCS-related CAP entries, NCS Infractions, and related documentation since the last inspection, including:

o CR-2024-1688 o

CR-2024-1767 o

CR-2024-1812 o

CR-2024-2687 o

CR-2024-2646 o

CR-2024-1617 o

CR-2024-2668 o

CR-2024-1303 E04-09-004, "Criticality Accident Alarm System Detector Coverage Calculations for Underground Storage Operations at the Framatome Richland Fuel Fabrication Facility," Version 1.0 "Evaluation of Reportability for UE-2024-001 CAAS Coverage with Respect to Below Grade Pits," dated August 8, 2024 FACILITY SUPPORT 88050 - Emergency Preparedness The inspectors evaluated selected aspects of the licensees emergency preparedness program to determine whether the program is maintained as required by the Emergency Plan, the license and license application, and NRC requirements in 10 CFR Part 70.

Emergency Preparedness Program Review and Implementation (IP Section 02.01)

The inspectors selected the following elements that support the implementation of the licensees emergency preparedness program to verify compliance with 10 CFR 70.22(i)(3), Chapter 8 of the license application, and the Emergency Plan. Specifically, the inspectors conducted the following inspection activities:

walked down the emergency equipment repositories in the Emergency Operations Center (EOC), Central Guard Station, and the Dry Conversion Facility (DCF) walked down the Alternate Emergency Operations Facility and the Joint Information Center (JIC) interviewed officials from select off-site support agencies - the Richland Fire Department (RFD), Benton County Emergency Management, and Franklin County Emergency Management (FCEM) reviewed changes to the emergency preparedness program, including annual updates to the Emergency Plan (EP), Emergency Plan Implementing

7 Procedures (EPIPs), and the Plant Emergency Response Team (PERT) and Plant Emergency Response Management Team (PERMT) rosters (see Documents Reviewed section) reviewed Memorandums of Understanding (MOU) agreements with off-site agencies (see Documents Reviewed section) reviewed training and site familiarization tour packets offered to the select off-site support agencies (see Documents Reviewed section) reviewed the training curricula for members of the PERT and PERMT and subsequently reviewed training records for select members from each group (see Documents Reviewed section) reviewed records and evaluations of recent drills and exercises (see Documents Reviewed section) reviewed the latest engineering change notice (i.e., plant modification) with an impact on the EP (ECN 9002, Hydrogen System Upgrade) and the associated hazard analysis (E14-01-010, North Tank Farm and Ancillary Service System, Version 6.0) reviewed work orders for emergency equipment inventory checks, quarterly phone checks with off-site support agencies, and equipment functionality checks (see Documents Reviewed section) reviewed Pre-Emergency Plans for select facilities and off-site resources such as municipal water, flammable gas, and electricity (see Documents Reviewed section Identification and Resolution of Problems (IP Section 02.02)

The inspectors reviewed the licensees identification and resolution of emergency preparedness issues to verify compliance with the license requirements. Specifically, the inspectors reviewed the following CAP entries, audits, or self-assessments:

CR 2023-1241, Lessons Learned from 2023 EP Field Exercise, 05/12/2023 CR 2023-1471, 2023 Q2 Horn Rapids Road (HRR) Criticality Evacuation Exercise, 06/16/2023 CR 2023-2454, 2023 Q4 HRR Criticality Evacuation Exercise, 10/18/2023 CR 2024-1589, 2024 Q2 HRR Criticality Evacuation Exercise, 06/21/2024 CR 2024-3174, 2024 Q4 HRR Criticality Evacuation Exercise, 11/04/2024 CR 2024-3317, Lessons Learned from 2024 EP Tabletop Exercise,11/15/2024 Audit / Surveillance No. 23:85, Internal Audit / Surveillance Report, 12/22/2023 Audit / Surveillance No. 24:4, Internal Audit / Surveillance Report, 09/12/2024

8 Event Review (IP Section 02.03)

The inspectors reviewed the licensees safety-significant and internal events related to emergency preparedness to verify compliance with 10 CFR 70.32(i), Chapter 8 of the license application, and the Emergency Plan. Specifically, the inspectors performed the following activities:

reviewed implementation of the EP associated with the following internal, nonreportable activations and temporary compensatory measures from January 2023 through October 2024:

04/20/2023 1102 hr - Fire in Lab Microwave o

Extinguished by lab staff o