ML24225A178

Framatome Document Request - 2024-003 - OPS2 & Pma

ML24225A178
Person / Time
Site:	Framatome ANP Richland
Issue date:	08/12/2024
From:	Gregory Goff NRC/RGN-II/DFFI
To:
References
EPID I-2024-003-0045 IR 2024003
Download: ML24225A178 (5)

Text

INSPECTION DOCUMENTATION REQUEST OPERATIONAL SAFETY

Document Request Date: Monday, August 12, 2024

Licensee: Framatome Inc.

Facility: Richland facility (Richland, WA)

Docket Number: 70-1257

License Number: SNM-1227, Amendment 18

Pre-Inspection Visit: N/A

Inspection Report Number: 2024- 003

Enterprise Number: EPID: I-2024- 003- 0045

Inspection Dates: September 09 -13, 2024

Inspection Procedure(s) (IPs): IP 88020 - Operational Safety IP 88070 - Plant Modifications ( Annual)

Inspector(s): Gregory (Gregg) Goff (Team Lead), e-mail: Gregory.Goff@nrc.gov Cynthia Taylor, e-mail: Cynthia.Taylor@nrc.gov Paul Startz, e-mail: Paul.Startz@nrc.gov Chad Oelstrom, e-mail: Chad.Oelstrom@nrc.gov

Accompanying Personnel: N/A

Identified Licensee Contacts:

Timothy Tate, EHS&L manager, timothy.tate@framatome.com Calvin Manning, Licensing and C ompliance manager, calvin.manning@framatome.com Brandon Hanson, L icensing & C ompliance manager-trainee, brandon.hanson@framatome.com Ernie Hockens, Operations Manager, ernie.hockens@framatome.com Jeff Marrozo, P lant Engineering Supervisor, jeffrey.marrozo@framatome.com

Inspection Document Request for NRC Inspection

The following is a broad list of documents the U.S. Nuclear Regulatory Commission inspectors are interested in reviewing prior to the on-site inspection visit. The current version of these documents is expected unless specified otherwise.

Please use electronic format(s) to provide the requested documentation (preferably as searchable.pdf files or Microsoft Word files). The NRC will provide BOX (a cloud-based file sharing service) to support this effort.

The documents provided in response to this request should contain sufficient information to facilitate the selection of specific inspection samples. Please know the NRC may request additional documentation during the inspection. The licensee is not required to provide documents that are already available in ADAMS.

If there are any questions or concerns regarding the information requested, please contact the NRC inspection team lead.

A. OPERATIONAL SAFETY-IP 88020

(See ML20324A732 for the latest procedure revision)

Focus Areas :

• System 120 - UNH Reprocessing

• System 130 - Conversion of UO2 Pellets to U308 Powder

• System 150 - MURS

• System 190 - Pellet Dissolution

• System 322 - UOx Powder Download Operation

• System 335 - TNF-XI Inner Powder Filling, Storage, and On Plant Movement

Documents Requested for In-Office Preparation

1. As noted above, the inspectors have selected Systems 120, 130, 150, 190, 322, and 335 as the focus areas. Please provide the following items below:

a. Current operational procedures, as applicable, showing the specific operation and implementation of the item(s) relied on for safety (IROFS):

For System 120, IROFS: 3506 (AEC), 3510 (AEC), 3511 (AEC), 3513 (AEC),

3516 (AEC), 3519 (AEC), & 3522 (AEC)

For System 130, IROFS: 1403 (EA), 3808 (AEC), & 3810 (EA)

For System 150, IROFS: 2347 (AEC), 6505 (AEC), 6517 (AEC), 6544 (AEC),

& 6643 (AEC)

For System 190, IROFS: 3209 (EA), 3219 (EA), 3225 (AEC),

& 3225.10 (AEC)

For System 322, IROFS: 1051 (AEC), 1502 (PEC), & 2242 (Admin)

For System 335, IROFS: 1102 (AEC), 1103 (AEC), 6406 (AEC), 6407 (AEC),

& 6408 (AEC)

b. Maintenance records for the IROFS above, as applicable.

c. Training records showing that training requirements for operators & maintenance staff, as applicable, for the selected IROFS have been completed.

d. Boundary definition documents, hazard analyses, and ISA meeting minutes for the IROFS 1051, 1102, 2347, 3225, 3513, 3808, & 6517. More could be added/requested later.

e. If applicable, complete configuration management package for recent changes affecting the selected IROFS (e.g., include older version of implementing procedures).

2. Latest version of the Integrated Safety Analysis (ISA) Summary for the six (6) focus areas (Systems 120, 130, 150, 190, 322, & 335).

3. Procedures governing the implementation of the following management measures, as applicable, to the IROFS selected above:

• Maintenance (general procedures)

• Training and Qualifications

• Procedures Development and Implementation

• Audits and Assessments

• Incident Investigations and Corrective Actions

• Records Management

• Quality Assurance (QA) for IROFS, as applicable

4. List of corrective actions generated in the last 12 months related to problems with the selected IROFS (e.g., IROFS failures or degradations).

5. List of plant changes implemented that affected the IROFS listed above since September 2023 including modifications to existing controls, elimination of previous controls, and addition of new controls.

6. List of changes in the Operations organization (E. Hockens division) in the last 12 months that were subject to the position-specific requirements of the license application.

7. List of compensatory measures implemented in the last 12 months to support degraded or failed IROFS. Please include a brief description of the compensatory measure, if practical.

8. If applicable, any audits/assessments of the focus areas, above as applicable to operational safety, within the last 12 months.

9. Contact information for key personnel expected to support the Operation Safety inspection.

10. Please provide a schedule or listing of planned IROFS surveillance, maintenance, operator training, and other significant site activities during the inspection week. This may have to be obtained after the maintenance or plan-of-the-day meeting on Monday, September 9th.

B. PLANT MODIFICATIONS (ANNUAL) - IP 88070

(See ML20324A731 for the latest procedure revision)

Documents Requested for In-Office Preparation

1. Procedure(s) for the configuration management system required per 10 CFR 70.72.

2. Procedures for the implementation of management measures for the configuration management system (e.g., post-modification testing, audits, training and qualification, and records retention).

3. Procedure used to implement changes to the license application.

4. List of corrective action program entries in the last 12 months related to plant modification issues.

5. Copy of latest self-assessment or audit for the configuration management system.

6. List and a brief description of facility changes implemented since January 2023. Please include all plant changes that affected IROFS and the ISA Summary, including modifications of existing controls, elimination of previous controls, and addition of new controls. Also specify if facility changes supported the sitewide AFM and/or AR activities.

7. Contact information for key personnel expected to support the Plant Modifications inspection.

Documents/Support Requested when On-site for Inspection

1. The inspectors may need additional documentation associated with the implementation of the changes listed in Item 6 above (Plant Modifications). Those documents may include engineering calculations, work orders, post-modification testing records, procedure revisions, training records, etc. Please provide such documents upon request.

2. The inspectors will need site support to conduct field observations, plant tours of selected plant modifications, operations, maintenance/functional testing of IROFS listed above and interviews with staff responsible for these activities.

3. Please inform the inspectors of any updates to the configuration management system that have occurred since this document request was issued.

4. Please provide a list of any plant meetings (0730 maintenance meeting, 0820 plan-of-the-day meeting, pre-job briefings, CAP review meeting, shift turnover, etc.).

PAPERWORK REDUCTION ACT STATEMENT

This letter contains mandatory information collections that are subject to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). The Office of Management and Budget (OMB) approved these information collections (approval number 3150- 0009). The burden to the public for these information collections is estimated to average 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />(s) per response. Send comments regarding this information collection to the FOIA, Library and Information Collection Branch, Office of the Chief Information Officer, Mail Stop: T6-A10M, U.S. Nuclear Regulatory Commission, Washington, DC 20555- 0001, or by e-mail to Infocollects.Resource@nrc.gov, and to the Desk Officer, Office of Information and Regulatory Affairs, NEOB-10202, (3150- 0009) Office of Management and Budget, Washington, DC 20503.

Public Protection Notification

The NRC may not conduct nor sponsor, and a person is not required to respond to, a request for information or an information collection requirement unless the requesting document displays a currently valid OMB control number.