IR 05000201/1979004
| ML19256E299 | |
| Person / Time | |
|---|---|
| Site: | West Valley Demonstration Project |
| Issue date: | 09/24/1979 |
| From: | Crocker H, Roth J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19256E297 | List: |
| References | |
| 50-201-79-04, 50-201-79-4, NUDOCS 7911020066 | |
| Download: ML19256E299 (13) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No. 50-201/79-04
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Docket No.,50-201 License No. CSF-1 Priority
Category RP Licensee:
Nuclear Fuel Services, Incorporated 6000 Executive Boulevard Rockville, Maryland 20352 Facility Name: West Valley Reprocessing Plant
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Inspection at: West Valley, New York Inspection conducted: August 28-30, 1979 Inspectors:
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A 9[,2f pf J. Rot W roject lnipector /
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/ / date'sigded date signed date signed Approved k
_,L 9/M/79 ff.11. CrocWChief, Fuel Facility f'
d(ge si(ned Projects Section, FF&?tS Branch Inspection Summary:
Inspection on August 28-30, 1979 (Report No. 50-201/79-04)
Areas Inspected:
Routine, unannounced inspection by a region-based inspector of the licensed program including:
10 CFR Part 21; organization; modifications and chances to facility and systems; internal review and audit; safety comittees; housekeeping controls; review of operations; nuclear criticality safety; routine use of packapes; periodic maintenance of packages; review of quarterly report; and, followup on IE Bulletins.
The inspection was initiated on the day shift and involved 23 inspector-hours on site by one NRC inspector.
Results: flo items of noncompliance or deviations were identified.
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Region I Form 12 (Rev. April 77)
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DETAILS 1.
Perso:'s Contacted
- J. P. Duckworth, General Manager / Plant Manager
- A. C. Pierce, Operations Manager
- R. T. Smokowski, Health and Safety Manager
- C. E. Seitter, Quality Assurance Supervisor
- C. W. AlJay, Plant Assistance Supervisor
- L. W. Wiademan, Mechanical Engineer The inspector also centacted 6 other licensee employees during the course of this inspection. These included shift foremen, operators, health and safety, maintenance, security and general office personnel.
- denotes those present at the exit interview.
2.
Organization The management organization now reporting to the General Manager, J.
P. Duckworth, is as follows:
J. P. Duckworth, Plant Manager J. F. Miller, Administrative Services Manager G. E. Kitchen, Security Supervisor The management organization now reporting to the Plant Manager, J. P.
Duckworth, is as follows:
A. C. Pierce, Operations Manager P. Burn, Technical Services Manager R. T. Smokowski, Health and Safety Manager C. E. Seitter, Quality Assurance Supervisor (Adminstratively)
The organization reporting to the Operations Manager, A. C. Pierce, is as follows:
A. G. Bockelman, Assistant Operations Manager J. W. Meade, Shift Supervisor G. E. Riethmiller, Shift Supervisor D. J. Sawyer, Shift Supervisor H. J. Shaffner, Shift Supervisor (Vacant), Training Coordinator L. W. Wiedemann, Mechanical Engineer R. E. Vandervort, Maintenance General Foreman L. J. Wiedemann, Maintenance Foreman r,
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The organization reporting to the Technical Services Manager, P. Burn, is as follows:
C. W. Alday, Project Manager C. W. Alday, Plant Assistance Supervisor L. Butler, Process Control Lab. Supervisory S. R. Greco, Emission Specialist and Standards Supervisor The organization reporting to the Health and Safety Manager, R. T.
Smokowski, is as follows:
G. W. Metzler, Health and Safety Specialist D. P. Wilcox, Health and Safety Specialist-Environmental D. C. Tharnish, Health and Safety Specialist-Industrial Safety T. M. Conlin, Health and Safety Specialist-Radiological Mr. W. A. Oldham, former General Manager / Plant Manager, died during mid June 1979, and Mr. J. P. Duckworth was named to the position of General Manager / Plant Manager shortly thereafter.
Mr. P. Burn was assigned as Technical Services Manager in place of Mr. Duckworth and Mr. C. W. Alday was assigned as Project Manager in place of Mr. Burn in addition to his previous position as Plant Assistance Supervisor.
Mr. B. H. Gilbert resigned as Training Coordinator during early August, 1979 and, as of the date of this inspection, no replacement has been assigned to this position.
This position is expected to be filled shortly.
The breakdown in number of people in the various groups is as follows:
Plant Manager
Operations Management
Operators
Maintenance
Technical Services
Health and Safety
Administrative Services 4 Security
Quality Assurance J
Presently, each of the four shifts have a supervisor and two operators.
Each shift has Health and Safety coverage between the hours of 6 a.m.
and 6 p.m. each day.
As of May 7, 1979, Mr. T. M. Conlin completed his training as the Health and Safety Specialist-Radiological and was placed on rotating shift.
Mr. D. P. Wilcox, who had been placed on the off-shift schedule for the duration of Mr. Conlin's training has been reassigned to the 8-4 shift as of May 7, 1979.
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3.
10 CFR Part 21 The inspector reviewed the procedure "10 CFR Part 21.21 Procedure",
dated December 27, 1977, and revised on January 3, 1978.
This document establishes and defines the criteria used for evaluation of substantial safety hazards and specifies the evaluation and reporting procedures required for the prompt notificaton of NFS management, specifies the required reporting sequence and establishes an internal facility evaluation committee as required by 10 CFR 21.21.
In addition, it was noted that the postings specified by 10 CFR 21.6 were in place as required.
4.
Operations R wiew - Nuclear Criticality Safety The inspector examined all areas of the site to observe operations and activities in progress, to inspect the nuclear safety aspects of the facility; and, to check the genaral state of cleanliness, housekeeping, and adherence to fire protection rules.
a.
Warehouse Storage The inspector noted that the licensee is maintaining a transfer jet syst.em anu the required transfer pipe which would be used in the event that a leak developed in the 8D-4 tank and the stored waste solution would have to be transferred to the 3D-3 spare tank.
Also stored in the warehouse is the piping to be used in the event that a leak developed and the waste solutions would have to be transferred from 8D-2 to the 80-1 tank as required by Technical Specification 5.4.3.
In addition, a spare pump for the system which was recently installed in the 80-1 tank is being maintained.
b.
Waste Tank Farm The inspector observed that a hole, dug in the Waste Tank Farm at the northeast corner of the instrument building, was surrounded by a yellow and white rope which appeared to designate this area as a contaminated or radiation zone.
Through discussions with licensee representatives, it was determined that this type of rope, without amplifying signs, could be used for industrial safety purposes.
However, the licensee representatives independently determined that employees commonly refer to this type of rope as
" radiation rope." Thus, use of this rope for other then radiation /
contamination control purposes has been discontinued.
A supply of "clotheslir.e" rope has been obtained by the licensee for use in industrial safety.
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c.
Laboratories The laboratories required to have a log of the special nuclear material present were examined.
Each laboratory had the log of material present conspicuously posted.
Each log was updated at it.ast once each week as required by procedures.
In addition, it was noted that each laboratory was posted with " Laboratory Crituality Control Procedures" which were last revised and updated on June 30, 1979.
d.
Radiation Monitors Radiation monitors located at selected locations throughout the facility were examined and appaared to be operating properly.
The remote readout meters for each monitor are located in the facility control room. All monitors were set to alarm at about 5 mr/hr with the exception of the monitor located in the FRS which was set to alarm at 10 mr/hr. All meters located in the control room appeared to be operating properly.
Licensee records examined by the inspector indicated that all area rudiation monitors had been calibrated quarterly between March 28,1978 and June 30, 1979.
The records also indicated that each unit which had been repaired, had been recalibrated prior to being placed inta service.
e.
Operating Procedures The inspector ccmpared the following operating procedures located at the appropriate work station in the Fuel Receiving and Storage (FRS) with the procedures contained in the master file located in the control room:
S0P l-8, Revision 8, dated April 1979, " Cask Unloading Crane";
S0P 1-9, Revision 6, dated April 1979, " Operation of Fuel Pool Canister Crane";
S0P l-10, Revision 6. dated April 1979, " Operation of Fuel Pool Service Bridge";
S0P l-12, Revision 11, dated March 1979, " Fuel Pool Water System",
S0P l-14, Revision 8, dated April 1979, "FRS Accountability";
S0P l-16, Revision 6, dated April 1979, " Operation of the Cask Onloading Pool Lift Rack";
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SOP l-34 Ravision 3, dated April 1979, " Operation of High Pressure Pump and Diesel Engine for FRS Decon Stall";
50P l-35, Revision 8, dated April 1979, "FRS Filter Medium and Resin Disposal and Replacement";
50P l-36 Revision 3, dat d November 1978, " Operation of the the New FRS Pool Cooling System";
50P l-38 Revision 3, dated March 1979, " Operation of the FRS Ventilation System";
SOP l-39, Revision 1, dated April 1979, "NFS-4 Cask Handling";
S0P 9-2 Revision 8, dated December 1978, " Solid Radioactive Waste Disposal";
S0P 15-9 Revision 7, dated March 1979, " Process Building Exhaust Fans";
S0P 15-14 Revision 8, dated December 1978, " Work in Contamination Zone 4 and High Radiation Areas";
S0P 15-26 Revision 2, dated July 1979, " Work in Contamination Zone 3";
It was determined that the procedures located at the work station were of the same revision and date as those located in the master file maintained in the control room as required by Technical Specification 7.1.3.
The inspector also examined the set of operational procedures maintained in the control room and determined that this set was current as required by Technical Specification 7.1.3.
5.
Safety Committee The inspector determined that the current membership of the Plant Safety Committee was as required by Technical Specification 7.1.1.6.
Current members include:
J. P. Duckworth, Plant Manager (Chairman)
A. C. Pierce, Operations Manager P. Burn, Technical Services Manager R. T. Smokowski, Health and Safety Manager C. E. Seitter, Quality Assurance Supervisor (Secretary, non-voting)
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The inspector examined the minutes of 11 Safety Committee meetings held for the period January 30, 1979, through July 30, 1979.
The committee met at least once each month and the quorum requirements of three of the four voting members or their alternates to be present were met in each case.
According to the minutes, the topics discussed at these meetings included a review and approval of special instruction procedures, standard operating procedures, emergency procedures, review of abnormal occurrences, discussion of the licensing problems associated with the NFS-4, NAC-1 shipping casks and a review of environmental,
considerations.
6.
Facility Changes and Modifications a.
High Level Waste Burial Area While the inspector was on site, the licensee initiated work to cover the used portions of the High Level Waste Burial ground with a 12 inch thick cap of topsoil in an effort to reduce or eliminate soil errosion.
Spreading of the top soil was completed on September 5, 1979 and seeding of the area with grass seed was scheduled to start on September 6, 1979.
b.
8D-2 to 80-1 Waste Tank Transfer Pipe The licensee has started reviewing procedures for the installation of permanent waste solution transfer lines between the used 8D-2 waste solution tank and the spare 80-1 tank.
Also being reviewed is the possible installation of permanent transfer pipe from the 8D-1 tank to the onsite low level waste water storage lagoons from which the waste water could be processed in the Low Level Waste Treatment Facility.
Examination of the status of this projected project will be followed during subsequent inspections.
(79-04-01)
7.
I_nternal Review and Audit a.
Annual Audit The inspector reviewed the corporate annual audit performed to fulfill the requirements of Technical Specifications 7.1.2.4 and 7.1.6.
The 1979 annual audit was conducted on May 29-30, 1979.
Recommendations were made concerning evacuation procedures; survey instrument placement, calibration, and response; and updating of criticality control procedures.
The licensee took necessary actions on the recommendations according to a June 25, 1979 reply letter.
No licensee identified items of nonocmpliance were identified during this annual audit of the Health and Safety status and practices at the West Valley, New York facility.
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b.
Quality Assurance Audits The licensee conducts internal audits under its quality assurance program.
The inspector examined the records of the audits conducted from January 1, 1979 through August 28, 1979. These records showed that the following number of audits were conducted during the time period reviewed.
Number of Audits Conducted Frequency Audits Performed Annual Requirement Monthly 313 612 Quarterly 154 276 Semi-Annual
2 Annual
54 Total 495 944 No reportable problems were disclosed in any of these audits conducted by the quality assurance department.
8.
Housekeeping The licensee has established procedures to ensure that good housekeeping is maintained on the site. These procedures call for quarterly house-keeping and safety inspectons to be performed by the Health and Safety-Industrial Safety Specialist. The inspection results are documented on a comprehensive checklist and on a summary page; this report is sent to the Health and Safety Manager.
Cognizant management is made aware of any items requiring corrective action.
A report highlighting problem areas is sent to the Plant Manager by the Manager of Health and Safety.
After about three weeks, the Industrial Safety Specialist performs a followup inspecton of the items which required corrective action.
The inspector examined the housekeeping reports for the second and third quarters of 1979. The reports from the Health and Safety Manager to the Plant Manager addressed the problem areas identified during the inspections and the corrective actions taken. The second quarter inspection was conducted May 14, 1979, and the third quarter inspection was conducted on August 14, 1979. The followup inspection for the second quarter was conducted on June 7,1979.
The followup inspection for the third quarter had not been conducted as of the date of this inspection.
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9.
Quarterly Reports Quarterly Report No. 53 for the period April 1,1979 to June 30, 1979, and dated July 25, 1979, was examined by the inspector.
It was determined that all information required to be reported by the facility Technical Specifications had been reported and corresponded to information documented in facility records.
10.
Technical Specifications The inspector examined licensee tickler file records and held discussions with licensee representatives concerning selected Technical Specifications.
a.
" Sump Alarms and Eductors" Licensee records indicated that the sump alarms and transfer eductors in the Product Purification Cell (PPC), Extraction Cell (XC-2) and Extraction Cell (XC-3) had been checked for operability at least once each month for the time period March 13, 1979 through August 28, 1979.
b.
Technical Specification 6.3.1 " Waste Storage Tank Pan Instrumentation" Licensee records indicated that the liquid level indicating instrumentation and the level alarm instrumentation for the pans and vaults of the 8D-1 and 8D-2 tanks were checked for operability at least once each month for the time period January 31, 1979 through August 29, 1979.
The level indicating instrumentation was changed to level recording instrumentation for the 8D-2 tank on January 25, 1979.
Instrumentation devices on the 80-2 tank, 8LI-15 and 8LI-5 were changed to 8LR-15 and 8LR-5, respectively.
The operability of the level indicating and level alarm instruments for the 8D-3 and 80-4 vault were also checked at least once each month during the same time period.
The 80-3 and 80-4 instruments were also calibrated on January 31, 1979.
c.
Technical Specification 6.4, " Emergency utility Equipment" Licensee records indicated that the emergency generator (30T-1),
the air compressor (31 K-1) and the cooling water pump 326-4B had been operated at least once every three months to determine the automatic start capability and performance under load as required by Technical Specification 6.4.1 during the time period January 9, 1979 through July 3, 1979.
Any malfunction identified was immediately corrected.
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According to licensee records, the boiler feed pumps (31 G-2A and 31 G-28), the boiler draft fans (31K-2 and 31K-2A) and the plant water pumps (32G-2A and 32G-28) had been operated at least once every three months to determine performance under load as required by Technical Specification 6.4.2 during the time period February 12, 1979 through August 12, 1979.
Licensee records examined by the inspector for the time period May 14, 1979 through August 27, 1979, indicated that the quantity of diesel fuel in oil tank (310-2) had been checked at least once each week to verify that at least 8,000 gallons of diesel fuel was being maintained in storage as required by Technical Specification 6.4.3.
Licensee records examined by the inspector for the time period January 9, 1979, through July 3, 1979, indicated that the auxiliary HEV blower (15F-21) and the main plant spare blower (15K-10A) had been operated at least once every 3 months to determine automatic start capability and performance under load as required by Technical Specification 6.4.4.
d.
Techncial Specification 7.1.3 " Plant Operation, Drills" The inspector de' ermined through examination of licensee records and through discussions with licensee representatives that energency drills have been held at sufficient frequency to ensure proficiency in emergency procedures as required by Technical Specification 7.1.3.
Thus far, during the calender year 1979, the licensee has held emergency drills for the A shift on April 30, 1979, for the D shift on May 11, 1979, and, for the C shift on June 12, 1979.
The emergency drill for the B shift will be held prior to the end of the calender year.
During the May ll, 1979 drill, the State of New York Warning Point, the West Valley Ambulance Service, the Chaffee Hospital, the Cattaraugus County New York Civil Defense Unit, Industrial Risk Insurers home office and NRC-Region 1 were advised that a drill was in progress.
No problem areas were identified in the conduct of the drill or in contacts with outside agencies.
Licensee records indicated that all aspects of the June 12, 1979 drill were satisfactory.
11.
Licensee Action on I&E Bulletins The inspector determined through discussions with licensee representatives that IE Bulletin No. 79-19, dated August 10, 1979, " Packaging of Low-Level Radioactive Waste for Transport and Burial" had been received and reviewed for applicability.
Since this licensee does not package and ship low level radioactive waste to off-site burial, it was concluded that this bulletin was not applicable to operations at this facility.
(79-BU-19)
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12.
Routine Use of Shipping Packages The inspector determined through discussions with licensee representatives that the licensee infrequently makes offsite shipments of other than exempt quantities of radioactive material.
Whenever significant quantities of radioactive materials are shipped off-site, the licensee prepares a Special Instruction Procedure (SIP).
The most recent transportation SIP prepared by the licensee was issued during March, 1979.
This document, SIP 79-3, Revision 0, dated March, 1979, "Prepara-tion for Shipment of 8D-2 Liquid Waste Sample to ORNL", was examined by the inspector as were other licensee documents concerned with this shipment.
It was noted that the shipping cask (a Model No. GE-8500 Uranium Shielded Shipping Cask Certificate No. 6697) was supplied by Oak Ridge National Laboratory (ORNL).
The sample packaging procedures were also supplied by Oak Ridge National Laboratory and incorporated into the licensee's procedure.
In addition, it was noted that an ORNL representative was on site during the sample preparation and packaging operations and that ORNL was, in f act, the shipper of this shipping container as evidenced by signature of the ORNL representative on all of the shipping documents.
The inspector determined through discussions with licensee representatives and examination of licensee records that all routine determinations and tests required by the federal regulations and the Certificate of Compliance had been completed prior to release of the cask to a carrier for transport to ORNL.
However, it was noted that records of the routine determinations conducted as required by federal regulations and packaging tests required by conditions 6 and 7 of the Certificate of Compliance had not been maintained.
Although it has been established, as previously noted, that the licensee was not the shipper and thus was not required to maintain these records, it was pointed out by the inspector that it was good industry practice to maintain these records in the event that a transportation incident should occur while the container was enroute to the destination.
In this situation, documentation would be available to show that all tests and determinations required had been completed prior to release of the container to the carrier.
All other documentation on this shipment was found to be in order.
This was discussed with licensee representatives at the exit *nterview and the licensee representatives stated that this type of documentation would be maintained on future shipments from the facility.
13.
Periodic Maintenance of Shipping Containers a.
Status of the Model NFS-4 Cask NRC issued an order on April 6, 1979 which required that all casks designated as the Model NFS-4 (NAC-1) should be withdrawn from use until a determination can be made of the exact nature of any deviations from the approved design and an assessment can be made of the safety significance of such deviations.
The order required that:
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1)
Effective immediately, the general license to use casks designated as Model No. NFS-4 is suspended pending further order of the Commission.
2)
Each owner / user shall show cause in the manner hereinafter provided why the general license to use cask Model No. NFS-4 should not remain suspended until such time as:
The owner / user demonstrates to the Commission that each cask was fabricated in accordance with the design approved by the Commission in Certificate of Compliance No. 6698.
This demonstration shall include review of the quality assurance records required by Condition 17 to Certificate of Compliance No. 6698 and actual physical measurements of existing packages.
This order was initiated after it was determined that one or more of the cask shells was warped or bowed and additional shielding material was being added to the outer shell of a cask in fabrication and thus, the cask (casks) may not have been fabricated in accordance with the design approved by NRC Certificate of Compliance No.
6698.
Investigation by the cask users have determined that several of the casks had a bow of about 0.170 to 0.180 inches, and some had an ovality of about 0.17 to 0.18 inches.
Specified bow is 0.130 inches and specified ovality is 0.135 inches.
As a result, the cask users must have all cask fabrication records audited by the NRC:IE Vender Inspection Program and must submit and have approved a new analysis (evaluation) to show that exceeding these specified tolerance levels would not adversely effect safety of the cask prior to being allowed to use the casks.
In addition, it has been determined that upon issue of the original approval to use these casks, analysis of cask buckling under accident conditions was not adequately addressed and must be reevaluated prior to next use of the casks.
It was determined by the inspector that because of suspension of the use of the NFS-4 casks, none of the casks currently at the licensee's site have had maintenance performed since. April 6, 1979.
Each of the casks will have to undergo the required quarterly maintenance checks and tests and the two NFS owned casks will have to undergo the required annual checks and test prior to the next use.
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b.
Thermal Performance Tests - NFS-4 Casks Certificate of Compliance No. 6698, Revision 8 in Condition 13 requires that the thermal performance of the cask shall be analyzed to verify that the cask operation has not degraded below that which is licensed at periodic intervals not to exceed three (3)
years.
The heat source used to conduct this test must be eqtal to at least 25% of the design heat load for the package.
Condition 5(b)(2) specifies 11.5 KW as the maximum decay heat load for the package.
The maximum acceptable temperature drop at the licensed heat load of the cask is 241.5 F with a heat load of 40,000 BTU /hr (11.7 KW).
The inspector examined the procedure SIP 79-6 NFS-4 " Spent Fuel Shipping Cask - 3 Year Thermal Test" dated May 1979, which established the procedures to be used for the conduct of this test and documented the results of a similar tests run during April and May 1976.
The 1979 tests were run on each of the NFS-4 casks during
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months of May and June 1979.
The following test results were obtained:
Thermal Test Results Temperature Drop (" F)
Cask No.
Initial 1976 Results 1979 Results NFS-4A 224 F 224 F 235.4 F NFS-4B 224 F 228.5 F 235.7 F Maximum allowable temperature drop 241.5* F.
As shown by the thermal test results, it was verified that each of the casks nad not degraded below the licensed thermal performance.
14.
Exit Interview The inspector met with the licensee representatives (denoted in paragraph 1) at the conclusion of the inspection at 11:00 a.m., on August 30, 1979.
The inspector presented the scope and findings of the inspection.
Subsequent to the inspection, on September 5, 1979, the inspector informed Mr. J. P. Duckworth, General Manager, that there were no items of noncompliance identified during the inspection.
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