IR 05000201/1980005
| ML19351E993 | |
| Person / Time | |
|---|---|
| Site: | West Valley Demonstration Project |
| Issue date: | 10/29/1980 |
| From: | Crocker H, Roth J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19351E992 | List: |
| References | |
| 50-201-80-05, 50-201-80-5, NUDOCS 8012190689 | |
| Download: ML19351E993 (21) | |
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O u.S. NuCteAR REcutAT0av COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No.
50-201/80-05 Docket No.
50-201 License No. CSF-l Priority
Category RP Licensee:
Nuclear Fuel Services, Incorporated 600 Executive Boulevard
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Rockville, Maryland 20352 Facility Name:
West Valley Reprocessing Plant Inspection at:
West Valley, New York Inspection conducted:
September 15-18, 1980 Inspectors:
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/0/r? M g Roth, Project inspector date signed date signed date signed Approved by:
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/4!& cfd H. W. Crgcker, Cfiief, Fuel Facil.ity dAte ' signed
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Projects Section, FF & MS Branch Inspection Summary:
Inspection on September 15-18, 1980 (Report No. 50-201/80-05)
Areas Inspected:
Routine, unannounced inspection by a region-based inspector of the licensed program including: -10 CFR Part 21; organization; modifications and changes to facility and systems; internal review and audit; safety connittees; requalification training; training; housekeeping controls; calibrations; surveil-lance testing; review of operations; nuclear criticality safety; confirmatory measurements-effluents (report only); transportation; review of quarterly reports; follow-up on licensee events; licensee action on previously identified enforce-ment items; follow-up on IE Bulletins; and, follow-up on headquarters requests.
The inspection was initiated on the day shift and involved 27 inspector-hours on site by one NRC region-based inspector.
Results:
No items of nonccmpliance were identified.
Region I Form 12 (Rev. April 77)
8012190b M
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DETAILS 1.
Persons Contacted
- J. P. Duckworth, General Manager / Plant Manager
- R. T. Smokowski, Health and Safety Manager
- C. E. Seitter, Quality Assurance Supervisor
- C. W. Alday, Plant Assistance Supervisor
- L. W. Wiedemann, Mechanical Engineer
- G. E. Riethmiller, Training Coordinator The inspector also contacted 11 other licensee employees during the course of this inspection.
These included shift foremen, operators, health and safety and general office personnel.
- denotes those present at the exit interview 2.
Licensee Action on Previously Identified Enforcement Items (Closed) Inspector Follow Item (201/78-06-02):
Comparison of licensee /
contractor sample splits with NRC analysis.
The inspector obtained the licensee and ifcensee contractor split sample anaylsis results.
Comparison of the data with NRS analysis results are presented in paragraph 19 of this report.
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(Closed) Inspector Follow Item (201/78-08-01):
Liquid Scintillation counter quench curve.
Through discussions with licensee representatives, the inspector determined that the licensee has obtained a copy of a book " Bio-logical Applications of Liquid Scintillation Counting" by Kobayoshi and Mandsley.
Based on information derived from this book the licensee has established a new quench curve and has been able to separate the following components of the curve including:
cosmic; counter construction material; facility background levels; and, vial and/or scintillator background.
(Closed) Event Report (201/79-ER-01):
Empty NAC cask with smearable contami-
nation exceeding 22,000 dpm per 100 cm beta activity arrived on site on April 4, 1979.
Theinspectorreviewedlicenseedocumentationwhichindicgted that two of 37 smears of the incoming cask exceeded the 22,000 dpm/100 cm acgivitylimit.
The maximum contamination observed was 25,720 dpm beta /100 cm.
No leaks or unusual conditions of the cask were observed.
The entire cask was decontaminated prior to the start of any work on this cask as indicated by licensee records.
(Closed) Infraction (201/80-01-02):
Failure of the quality assurance supervisor to verify the conformance of purchased filters to the specifica-tions.
The inspector verified that the filters in questian had been quaran-tined (set aside so that they would not be used) until the missing certifica-tion documentation had been received.
A new copy of the " Certificate of
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Compliance" and the " Flanders Test Report" dated October 5, 1979 were received by the licensee on January 21, 1980.
A. duplicate set of these documents was being kept on file in the quality assurance suppervisor's office.
Corrective action has been completed on this item of noncompliance.
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3.
Review of Operations
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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 general state of cleanliness, housekeeping and adherence to fire protection rules.
a.
Analytical Laboratory Hot Cells During examination of the hot cell facilities, the inspector observed that large plastic buckets (in excess of one liter in volume) were stored in each hot cell.
Item VII of the " Laboratory Criticality Control Procedures" states that "Nowhere in the Laboratory Area shall containers larger than one liter capacity be used for the storage of fissionable material solutions" The posted inventory sheet for the hot cells indicated that less than four liters of SNM bearing solutions were present as authorized by Item VI.
A licensee representative stated during the exit interview that the large plastic buckets were used to store contaminated waste generated in the hot cell.
This practice will be reviewed and smaller containers will be used for the storage of contaminated waste if it is found to be appropriate.
No items of noncompliance were identified.
b.
Log Books
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l The inspector examined the log book maintained in the waste tank farm shelter.
The log book contained entries indicating the time of day, date, shift and individual taking instrument readings.
It also indica-ted any identified problem areas.
The shift supervisor's log book located in the shift supervisor's office was examined R.'. random for the period January 1,1980 through September 17, 1980.
Entries in the log consisted of instructions to shifts, logging of shift experiences, and actions taken regarding shift operations.
Each shift supervisor reads each entry and verifies this action by initialling the log book.
No items of noncompliance ~were identified.
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c.
Operating Procedures The inspector compared the following operating procedures located at the appropriate work station in the Waste Tank Farm (WTF) and the Chemical Operating Aisle (COA) with the procedures contained in the file located in th? control room:
(1) WTF Procedures TOP-8-2A Revision 3, dated June,1580
" Waste Tank 80-1 Solution Disposal" SOP-8-1 Revision 14, dated December, 1979
" Waste Tank Operation" SOP-9-2 Revision 8, dated December,1979
" Solid Radioactive Waste Disposal" (2) COA Procedures 50P-9-2 Revision 8, dated December, 1979
" Solid Radioactive Waste Disposal"
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50P-15-4 Revision 12, dated September, 1980 l
"'B' and 'C' Type Sample Operations" The inspector determined that the procedures located at the work stations were of the same revision and date as those located in the file located in the control room as required by Technical Specification 7.1.3.
The inspector also examined other procedures, ac random, being maintained in the control room and determined I
I that these procedures were also current revisions as required by Technical Specification 7.1.3.
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No items of noncompliance were identified. *
d.
Sanitary Landfill
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The inspector examined a sanitary lardfill located on the site approxi-mately 130 yards east of the " hardstand" storage' area. Through dis-cussions with licensee representatives, it was determined that only industrial waste and trash which had been demonstrated to be uncontami-
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nated with radioactive materials have been buried in this landfill area.
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4.
Organization The management organization reperting to the General Manager (West Valley),
J. P. Duckworth as of July 1,1980, is as follows:
J. P. Duckworth, Plant Manager J. F. Miller, Administrative Services Manager G. E. Kitchen, Security Supervisor A. C. Pierce, Operations Manager P. Burn, Technical Services Manager R. T. Smokowski, Health and Safety Manager C. E. Seitter, Quality Assurance Supervisor (Administrative 1y)
The organization reporting to the Operations Manager, A. C. Pierce, is as follows:
A. G. Bockelman, Assistant Operations Manager J. W. Meade, Shift Supervisor D. J. Ploetz, Shift Supervisor D. J. Sawyer, Shift Supervisor H. J. Shaffner, Shift Supervisor G. E. Riethmiller, Training Coordinator L. W. Wiedemann, Mechanical Engineer R. E. Vandervort, Maintenance General Foreman L. J. Wiedemann, Maintenance Foreman
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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. Supervisor (part-time)
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 Supervisor D. P. Wilcox, Health and Safety Specialist-Environmental D. C. Tharnich, Health and Safety Specialist-Industrial Safety T. M. Conlin, Health and Safety Specialist-Radiological Mr. L. Butler is currently working at the facility as the Process Control Laboratory Supervisor on the swing shift on a part-time basis.
During normal operating hours, his duties have been assigned to S. Greco, the Emission Specialist and Standards Supervisor.
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'One operator D. Lichey resigned from the facility on July 3, 1980 and a replacement Mr. R. Miller (a former operator) was hired on August 1,1980.
Mr. Miller is currently in training and has been assigned work not involving the handling of radioactive material.
The inspector determined that the Manager, Health Physics has been certified as a certified Health Physicist by the Health Physics Society.
The breakdown in the number of people in the various groups is as follows:
Plant Manager
Operations Management
Operators
Maintenance
Technical Services
Health and Safety
Administrative Services
Security
Quality Assurance
49 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.
No items of noncompliance were identified.
5.
Nuclear Criticality Safety a.
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 least once each week as required by procedures.
In addition, it was noted that each laboratory was posted with " Laboratory Criticality Control Procedures" which were last revised and updated on June 30, 1979. The use of containers in excess of one liter in size in the hot cells was previously discussed in paragraph 3a.
No itecs of nonccmpliance were identified.
b.
Radiation Monitors Radiation monitors located at selected locations throughout the facility were examined and appeared 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. All meters located in the control room appeared to be operating properly.
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Licensee records examined by the inspector indicated that all area radiation monitors had been calibrated quarterly between June 30, 1979 and June 26, 1980.
The records did not indicate that each unit which had been repaired, had been recalibrated prior to being placed back into service.
This was discussed at the exit interview.
Licensee management indicated that each repaired unit had been recalibrated prior to going back into service but the records had not been maintained.
No items of noncompliance were identified.
6.
10 CFR Part 21 The inspector reviewed the procedure "10 CFR Part 21.21 Procedures" dated December 27, 1977 and revised on January 3 and January 27, 1978. These documents established and defined the criteria used for the evaluation of substantial safety hazards, specified the evaluation and reporting procedures required for the prompt notification of NFS management, and specified the required management reporting sequence. A memo dated January 20, 1978 established an internal facility evaluation committee as required by 10 CFR 21.21.
This committee consists of:
The General Manager as Chairman, the Cperations Manager, the Technical Services Manager, the Health and Safety Manager, the Security Manager, and the Quality Assurance Supervisor.
Evaluations are to be performed by at least two of the above with expertise in the area of concern.
This evaluation is then presented to the full committee for consideration.
In addition the inspector observed that the notices specified by 10 CFR 21.6 had been posted at facility entrances as required.
No items of noncompliance were identified.
7.
Safety Committee The inspector determined that the current membership of the Plant Safety Committee was as required by Technical Specification 7.1.1.6.
The inspector examined the minutes of 13 Safety Committee meetings held from January 14, 1980 through September 10, 1980.
The committee met at least at the required frequency 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:
review and approval of standard operating procedures, corrective actions to be taken to repair a boiler (see paragraph 12a for additional detail), review of a special procedure concerned with the disposal of solution from waste tank 80-1, and, revision of the plant wide " Shutdown Run Plan" and " Letter of Authorization."
No items of noncompliance were identified.
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8.
Internal Review and Audit The licensee conducts internal audits under its quality assurance program.
The inspector examined records of the audits conducted from January 1,1980 through September 11, 1980.
These audits cover technical specification, 10 CFR 19, 10 CFR 20, 10 CFR 71, SNM-984, Security, and Special Nuclear Material Control requirements.
The records showed that the following number of audits were conducted during the time period reviewed.
Number of Audits Conducted Frequency Audits Performed Annual Requirement
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Monthly 351 492 Quarterly 173 240 Semiannual
2 Annual
43 Total 555 777 Review of licensee records indicated that all of the audits required to date had been performed.
No problem areas were identified during the conduct of any of these audits performed by the Quality Assurance * Super-visor.
No items of noncompliance were identified.
9.
Housekeeping The licensee has established procedures to ensure that good housekeeping is
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maintained on the site.
These procedures call for quarterly housekeeping and safety inspections 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 follow-up inspection of the items which required corrective action.
The inspector examined the house-keeping reports for the fourth quarter of 1979 and the first three quarters of 1980.
The reports from the Manager Health and Safety to the General Manager addressed the problem areas identified during the inspections and the corrective actions taken.
No items of noncompliance were identified.
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10. Quarterly Reports Quarterly Report No. 56 for the period January 1, 1980 to March 31, 1980 was examined by the inspector.
It was determined that all information required to be reported by the facility Technical Specifications had been recorted and corresponded to information documented in facility records.
No items of noncompliance were identified.
11.
Facility and Equipment Chances and Modifications No items of noncompliance were identified.
a.
Low Level Waste Burial Ground On September 3, 1980, the licensee initiated work to repack the surface of trenches 11,12,13, and 14 of the South Low Level Waste Burial area.
This work was done in order to seal the cover over the burial trenches.
The inspector determined that the six inch layer of top soil was being removed, the next three feet of cover was being removed and the next 12 inches of cover was being plowed.
The soil was then being replaced in about 8 inch layers and compacted to about 90%
density.
Upon replacement and compaction of the cover soil, a 12 inch layer of top soil wil' be placed on the trenches, graded and seeded.
This work is scheduled for completion by October 15, 1980.
The inspector
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observed the cover being removed from trench 12 and replaced onto trench 11.
b.
80-1 Pumpout Waste tank 80-1 was pumped out to a level of about 113,000 gallons of solution during the months of June and July, 1980.
About 80,000 gallons of solution was treated through an appropriate ion exchange system, released to the site waste liquid lagoon system, retreated in the Low Level Waste Treatment Facility and released from the site.
An additional 60,000 gallons of solution from the 80-1 tank was placed back into the 8D-2 waste tank.
c.
Restricted Area Fence Line The licensee has improved the ground area adjacent to the restricted area fence so that the fence line can be examined by vehicle under any type of weather conditions.
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8D-2 Vault Vent System The licensee has designed and is fabricating a vapor collection /
condensing system which will facilitate the analysis of tritium in off gas (steam) condensate released from the 80-2 vault. Installation of this system is expected to be completed by December 1, 1980.
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l e.
North Steam Boiler On January 14, 1980 the North Boiler attached to the west wall of the Utility Room experienced an explosion in the fire box which damaged the boiler and associated piping.
On January 23, 1980 a standby rental boiler was received and set into place.
Installation and testing of the rental boiler were completed by February 12, 1980.
Reconstruction, recertification, and testing of the North Boiler was completed by May 16, 1980.
For additional detail on this incident see paragraph 12a.
12.
Nonroutine Events i
No items of noncompliance were identified.
a.
North Boiler
'On January 14 at 1100 hours0.0127 days <br />0.306 hours <br />0.00182 weeks <br />4.1855e-4 months <br />, the North Boiler experi'enced an explosion in the firebox which damaged the boiler and associated piping.
No radioactive material was involved and no damage to the plant, except for the boiler occurred.
No plant personnel were injured.
Piping common to both the North and South Boilers was repaired immediately and the South Boiler was placed on-line upon completion of these repairs. The explosion opened up welded seams on the two sides of the firebox and the west end of the firebox was dislocated about 2-3 inches.
Region I was notified of this incident on January 15, 1980.
The licensee received a rental boiler on January 23, 1980 and completed installation and testing of this boiler by February 12, 1980.
The rental boiler was to be used as standby unit in case of a malfunction of the South Boiler.
The rental boiler was placed on line on March 3, 1980, when the South Boiler shut down due to a shorted alternator which supplies power to the boiler electrical circuitry, until the South Boiler repairs were completed.
The North Boiler was refurbished,
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rebuilt, tested, recertified and placed back into operation by May 16, 1980.
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b.
Water Supply Pump The inspector was informed on September 15, 1980 by the licensee that
the pump used to obtain some facility water from a lake onsite was hit by lightning on the morning of September 14, 1980 and was not operational.
The licensee indicated that there was an adequate water supply available for operation of the facility.
The inspector verified that the pump was repaired and back in operation on September 10, 1980.
13.
Instrument and Equipment Calibration The inspector reviewed and evaluated the adequacy of schedules established by the licensee for calibrating equipment and instruments associated with systems important to safety.
No items of noncompliance were identiff'ed, a.
Required Calibracions The inspector reviewed the records foh the calibration of radiation monitors and determined, as discussed previously in paragraph 5b, that the radiation monitors used throughout the facility have been calibrated on a quarterly frequency.
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b.
Other Calibrations The inspector examined records of the calibration of pieces of equip-
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ment associated with the systems important to safety in the Waste Tank Farm.
The equipment records examined, and the calibration frequency are indicated below.
Specific equipment examined by the inspector is indicated by a notation of the last date calibrated.
Last Date Instrument Description Frequency Calibrated (1)
8-LAH-1 801 Pan High Level Semi-annual 7/24/80 (2)
8-LAH-3 8D6 K0 drum High Level Semi-annual (3) 8-LAH-7 802 Fan High Pressure Semi-annual 7/24/80 j
(4)
8-LAH-9 8D3 Tank High Level Semi-annual (5)
8-LAH-10 803 Sump High Level Semi-annual (6) 8-LAH-11 804 Tank High Level Semi-annual (7) 8-LAH-12 8C1 Off Gas Scrubber High Level Semi-annual 7/23/80 (8) 8-LAH-19 801 Vault High Level Semi-annual 7/24/80 (9) 8-LAH-20 802 Vault High Level Semi-annual 7/24/80 (10)
8-LAH-25 8010 & 8010A High Level 2 Months (11)
8-LAH-13 8C1 Off Gas Scrubber
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Low Level Semi-annual 7/27/80
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i (12) 8-PAH-2 801 Tank High Level Semi-annual (13) 8-PDAH-4 8T1 & 8T1A Off Gas Filters
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High D/P Semi-annual (14) 8-PAH-5 8K1 & 8X1A Blower Inlet High Pressure Semi-annual (15) 8-PAH-8 802 Tank High Pressure Semiannual (76) 8-PDAH-26 Filter 871 D/P Semi-annual (17) 8-PDAH-26A Filter 8T1A D/P Semi-annual (18) 8-FAL-18 Caustic to 8C1
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Low Pressure Semi-annual (19) 8-PAL-22 Low Instrument Pressure Semi-annual (20) 8-TAH-15 Con Ed Tanks High Temp.. Semi-annual (21) 8-TAL-19 806 Condensate Tank low Temperature Semi-annual 14.
Surveillance Testina - Technical Specifications The inspector reviewed licensee records and held discussions with selected licensee representatives concerning selected Technical Specification,s.
No items of noncompliance were identified.
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a.
Technical Specification 6.2.1, Sump Alarms and Eductors Licensee records indicated that the sump alarms and transfer eductors in the Product Purifcation Cell (PPC), Extraction Cell No. 2 (XC-2)
and Extraction Cell No. 3 (XC-3) had been checked for operability at least once each month for the time period August 26, 1979 through September 9, 1980.
b.
Technical Specification 6.3.1, Waste Storage' Tank Pan Instrumentation
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Licensee records for the time period July 23, 1979 through September 11, 1980, of the periodic verification of the operability of instrumen-tation for the presence of liquid in the 80-1 and 8D-2 tank pans were examined.
The records showed that the licensee verified the operation of the liquid level indicating-instrumentation and the level alarm instrumentation for the pens and vaults of the 80-1 and 8D-2 tanks at least once each month.
The operability of the level indicating and level alarm instruments for the 80-3 and 80-4 vault were also checked at least once each month during the same time period.
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c.
Technical Specification 6.4, Emergency Utility Equipment According to licensee records, the emergency generator (30T-1), the air compressor (31K-1) and the cooling water pump 32G-48 had been operated at least once every three months to determine the automatic start capability and performance under load.
Licensee records indicated that these tests had been conducted as required by Technical Specifica-tion 6.4.1 during tha time period July 3, 1979 through July 8, 1980.
According to licensee records, the boiler feed pumps (31G-2A and 31G-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 each three months to determine performance under load.
Licensee records indicated that these tests had been conducted as required by Technical Specifica-tion 6.4.2 during the time period August 12, 1979 through August 12, 1980.
Licensee records examined by the inspector for the time period May 26, 1980 through September 15, 1980, indicated that the quantity of diesel fuel in oil storage tank (310-2) had been checked at least weekly 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 July 23, 1979 through September 11, 1980, indicated that~the auxiliary HEU 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 Specifica-tion 6.4.4.
No items of noncompliance were identified.
15.
Licensee Action on IE Circulars and Bulletins a.
IE Circular 80-14 The inspector determined through discussions with licensee repre-sentatives that IE Circular 80-14, dated June 24, 1980 " Radioactive Contamination of Plant Demineralized Water System and Resultant Contam-ination of Personnel" had been received and reviewed for applicability.
The licensee has examined all potential sources of contamination of the plant demineralized water system and concluded that with the facility in suspended operation, the demineralized water system cannot be inadvertently contaminated.
However, there may be a potential for contaminating the demineralized water system should the plant be reactivated.
Should this occur, safety committee reviews of operating procedures should be cognizant of this hazard. An official letter has been issued to all employees which prohibits the use of plant supplied
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demineralized water for human consumption. The letter also states that the potable water system is the only authorized source of water at the site for human consumption.
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b.
IE Bulletin 80-15 The inspector determined through discussions with '44 Wiec retresenta-tives that IE Bulletin 80-15, dated June 18, 1987 t*wesible Less of Emergency Notification System (ENS) with Loss of Offstte Prisr" had been received and reviewed for applicability.
In t e licensee's response dated June 26, 1980, it was stated that the licensee had determined, in response to Action Item 1, that the ENS telephones at the West Valley plant were supplied with power by the telephone company (Iroquois Telephone Company).
Tnese telephones do not receive power from the onsite power supplies.
Therefore, no onsite auxiliary power supply was required.
Through examination of licensee records, the inspector determined that tests of the ENS telephones, as required by Action Item 3, were conducted on all extensions during losses of offsite power to the facility on July 7, 1980 and on July 21, 1980. No problem areas were identified during these tests.
The inspector also determined that the licensee has issued a directive to applicable personnel which includes a statement of the NRC notification requirements as required by Acticn Item 5.
The licensee has also prepared an information package which has been placed at each ENS telephone extension location.
This information package contains a telephone log, the statement of notification requirements, a copy of Bulletin 80-15 and the licensee's response dated June 26, 1980, copies of all correspondence received by the licensee from the NRC which discussed both the ENS and the HPN telephone systems, and, copies of applicable federal regulations (i.e. 10 CFR 20.403 " Notifications of Incidents" and 10 CFR 50.72
" Notifications of Significant Events").
l No items of noncompliance were identified.
!
16.
Transportation No items of noncompliance were identified.
a.
Quality Assurance Program
!
On October 8, 1978 the licensee submitted a quality assurance program for radioactive material transport activities at the facility. The document titled " Quality Assurance Program for Certificate of Compliance Number 6698" only included information relative to the NFS-4 Spent
. Fuel Shipping Cask.
On April 6,1979 the NRC ordered the NFS-4 casks withdrawn from use and on June 5, 1979, NRC requested additional information relative to the October 8, 1978 QA program submittal.
Subsequently, the licensee decided to modify the facility QA program l
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for operations to include the packaging of radioactive materials.
The modified QA program for transportation was submitted to NRC-NMSS by letter dated September 4, 1979.
In a letter dated September 11, 1980 NRC-NMSS informed the licensee that the facility QA program for operations as modified for transportation does not meet the requirements of 10 CFR 71.51(d).
As a result, since the licensee does not intend to use the Model NFS 4 casks, a modified QA program for transportation will be resubmitted to NRC-NMSS to meet the requirements of 10 CFR 71.51(a).
b.
Status of NFS-4 Casks A and B The inspector determined through discussions with licensee representa-tives that the two Model NFS-4 casks owned by the licensee have been out of service and have not been licensed for use since April 6,1979.
Nuclear Assurance Corporation (NAC) has apparently expressed an interest in buying the two NFS-4 casks from NFS.
NAC has also prepared and submitted to NRC-NMSS a general revision to the Safety Evaluation Report for the Model NFS-4 casks.
This document was dated May 21, 1980.
NAC has proposed to remove the present approximately 43 inch diameter impact limiters from the Model NFS-4 casks and replace the impact limiters with removable units which are approximately 72.3 inches in diameter.
The larger diameter impact limiters are expected to absorb sufficient dropping energy to preclude deformation of the
-
inner cask wall during an accident.
The inspector also determined that the Model NFS-4 cask was restricted to a dry heat load limit of 2.5 kw per the results of an analysis l
performed and submitted to NRC-NMSS with a letter dated December 24, i
1975.
i 17.
Training a.
New Employee Training The inspector examined the documentation for the training of a new employee.
This new employee started on July 28, 1980 and completed Health and Safety indoctrination training on August 5,1980.
This training included the following topics:
Theory of radiation, use of instruments, contamination zones, radiation areas, calculation of dose rates, dose limits, decontamination procedures, chemical safety, fire
safety, evacuation procedures, general plant safety, facility contin-gency procedures, industrial safety and a tour of the plant.
The extent of retention and comprehension of the information presented was l
determined by means of written quizzes.
The inspector examined the
!
quizzes and determinea that this new employee had obtained and retained a fundamental knowledge of the material covered.
This was later verified during an interview with this individual.
The inspector noted that the quiz papers in this individual's file had not been
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dated to indicate the day on which the quizzes were taken. This was discussed with licensee representatives since dating of these quizzes would serve to complete the chronological record of the initial training given to any new employee.
The licensee representatives stated that this comment would be reviewed and new employee quizzes would be dated if deemed necessary.
Section 4.2c of the plant health physics manual states that "whole body counts are taken on all radiation workers prior to employment.
.." From this employee's record, it was determined that a whole body count had not been taken on this individual prior to employment.
Licensce representatives indicated that this employee was not given a whole body count because the counter was not working properly when the individual started employment.
In addition, this individual was not hired as a radiation worker and during the exit interview the licensee stated that he would be given a whole body count prior to his assignment as a " radiation worker." During a telephone discussion on October 3, 1980 with the Manager, Health Physics, the inspector was informed that the facility Health Physics Manual had been modified, formally, to require whole body counting of personnel prior to " assignment" as a radiation worker rather than prior to employment.
No items of noncompliance were identified.
~
b.
Ongoing Safety Training According to licensee records examined by the inspector, during the year 1979, safety meetings were held at least monthly with personnel from each operating shift attending.
Topics covered during these meetings included emergency procedures, review of the Health and Safety Manual, required actions during an emergency, protection and detection devices, fire sprinkler systems, hands-on use of fire fight-ing equipment, and, safety attitudes.
It was also determined through discussions with licensee representa-tives that all of the plant Health Physics Technicians were preparing to take the tests required to be certified by the National Registry of Radiation Protection Technicians (NRRPT).
These tests were scheduled to be given on October 4, 1980.
No items of noncompliance were identified.
c.
Requalification Training The licensee's requalification program is based in large measure on a written test and a " Walk Through" test system.
There is currently only one type of license. This is a plant-wide operator's license.
There are currently two categories of operators, senior operators
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(including plant management and shift supervisors) and operators. The plant-wide operator's license will be maintained while the plant is being operated in a shutdown condition.
If and when the plant resumes normal operation, each operator will then have to be requalified on the various plant operating systems.
According to licensee records, there are 8 senior operators and 11 operators currently licensed at this facility and one new employee is in training to become an operator.
The inspector reviewed the records of the requalification and quali-fication testing of the plant operators.
NRC administered written tests were given on the Low Level Waste Treatment Facility on March
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17, 1980, on Plant-wide Operations on March 18, 1980, and the Plant Walk Through tests were conducted on March 19-20, 1980.
All operators passed the exams and the new licenses were issued on March 24, 1980.
Licensee records also showed that the operators were given procedures for responding to abnormal or emergency conditions and Standard Operating Procedures on a quarterly schedule.
Each operator reviewed the procedures listed on the " Quarterly Abnormal, Emergency, and, S0P Review Checklist" with his supervisor and signed the checklist certify-ing that he had read and understood the contents of the reviewed procedures.
It was determined that the " checklist" procedures are 3 months behind the actual calendar quarter.
For example, procedures issued during the second quarter of the year must be reviewed and the sign-off sheet returned to the training coordinator prior to the end of the third quarter of the year.
Licensee records also indicated that the operators (senior operators and operators) were given an annual appraisal of the performance of their licensed duties.
In each case the appraisal was conducted by the next higher level of menagement.
In all cases, the performance of the operators was rated as being satisfactory.
No items of noncompliance were identified.
l 18.
Subsurface Water Monitoring Well System The inspector determined through discussions with licensee representatives and review of licensee records that this licensee has been monitoring radioactivity in subsurface water through the means of a monitoring well system since about mid 1974.
The licensee has installed and has been sampling up to 34 wells. Wells 1 through 5 were installed in 1974 around the old interceptor Lagoon 1 ares and were abandoned during 1977.
Wells A through F were installed during 1977 around the interceptors, Lagoon 1 area, and the drainage area for the French Drain which was installed in 1965.
An additional 26 wells were installed during 1978 to intersect ground water flowing in the direction from the low level waste treatment facility, the FRS, the process building and/or the waste tank farm to the
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northeast swamp.
Two additional wells were installed during 1979 to inter-sect water flowing from Lagoon 3.
Licensee analysis of the data obtained between 1974 and 1979 indicated that:
tritium was the only significant (above background) radioactive isotope found in the ground water; there has not been any significant additions of tritium to-the ground water since 1977, and tritium activity in the northeast swamp and the French Drain has been decreasing since 1977.
The licensee has continued sampling all of the monitoring wells annually; two wells 0 and G are sampled and analyzed quarterly.
Well D is located at the northwest corner of Lagoon 1 and Well G is located at the northeast corner of Lagoon 1.
All of the wells had been sampled by the licensee during the week of September 8, 1980. However, analysis of all the samples had not been completed by the end of this inspection.
No items of noncompliance were identified.
19.
Confirmatory Measurements - Liquid Effluents Comparison of the licensee's measurements with those of the NRC for liquid effluent samples split during an inspection on June 6-8, 1978 (Inspection Report No. 50-201/78-06) are tabulated in Tables 1 and 2 attached.
The Table 1 comparison of NRC results with licensee contractor results indicated that three measurements were in agreement or possible agreement and two measurements were in disagreement.
The Table 2 comparison of NRC results with licensee in-house results indicated that one measurement was in agree-ment and two measurements were in disagreement.
The test criteria used by the Office of Inspection and Enforcement for comparing test results is given in Attachment 1.
The inspector conducting the comparison noted that in Table 1 one of the licensee's values was higher or more conservative that the NRC values and one of the licensee's values was lower. In Table 2, the two licensee in-house values in disagreement were higher than the NRC values.
This disagreement was in a conservative direction and since the licensee in-house values are used for release of effluent from the site, this would not result in the licensee exceeding any technical specification
.
liquid effluent release limits.
An inspector will take an in-depth look at
!
licensee procedures and methodology during a subsequent inspection in order to resolve the disagreements (80-05-01).
No items of noncompliance were identified.
20.
Exit Interview l
The inspector met with licensee representatives (denoted in paragraph 1) at the conclusion of the inspection at 1:00 pm on September 18, 1980.
The inspector presented the scope and findings of the inspection and stated that no items of noncompliance were identified during this inspection.
Remarks made by licensee representatives during the exit interview have been incorporated into the applicable paragraphs of the inspection report details.
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TABLE 1 NFS - Verification Test'Results - Contractor
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SAMPLE IS0 TOPE NRC VALUE LICENSEE VALUE
'COMPARIS0N
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RESULTS IN MICR0 CURIES'PER~ MILLILITER Lagoon #5
6/8/78
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gross beta (3.4310.14)E-6 (7. 2710.15)E-6 Disagreement
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Co-60 (2.81+0.49)E-7 (1.010.1) E-7 Disagreement
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Sr-90 (1.2410.08)E-7 (1.6610.05)E-7 Possible Agreement
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Cs-134 (2.4810.48)E-7 (2.410.2)E-7 Agreement i
Cs-137 (3.4310.16)E-6 (2.8210.09)E-6 Agreement
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TABLE 2 NFS - Verification Test Results -'In-House
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SAMPLE IS0 TOPE NRC VALUE LICENSEE VALUE COMPARIS0N RESULTS IN MICR0 CURIES'PER' MILLILITER Lagoon #5
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. 6/8/78 gross alpha (2.410.2 )E-8
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gross beta (3.4310.14)E-6 (1.4910.14)E-5 Disagreement H-3 (6.8010.03)E-4 (7.7610.08)E-3 Disagreement Cs-137 (3.4310.16)E-6 (3.1817)E-6 Agreement
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Attachment 1
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i Criteria for Comparing Analytical Measurements I
This attachment provides criteria for comparing results of capability tests and verification measurements.
The criteria are based on an empirical relationship which combines prior experience and the accuracy
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needs of this program.
In these criteria, the judgement limits are variable in relation to the
l comparison of the NRC Reference Laboratory's value to its associated
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uncertainty.
As that ratio, referred to in this program as " Resolution",
increases the acceptability of a licensee's measurement should be more j
selective.
Conversely, poorer agreement must be considered acceptable as the resolution decreases.
,
LICENSEE VALUE l
RATIO = NRC' REFERENCE VALUE Possible Possible Resolution Agreement Agreement A Agreement B
<3 0.4 - 2.5 0.3 - 3.0 No Comparison 4-7 0.5 - 2.0 0.4 - 2.5 0.3 - 3.0 8 - 15 0.6 - 1.66 0.5 - 2.0 0.4 - 2.5
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16 - 50 0.75 - 1.33 0.6 - 1.66 0.5 - 2.0 51 - 200 0.80 - 1.25 0.75 - 1.33 0.6 - 1.66
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>200 0.85 - 1.18 0.80 - 1.25 0.75 - 1.33
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"A" criteria are applied to the following analyses:
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l Gamma Spectrometry where principal gamma energy used for identification l
1s greater than 250 Kev.
i Tritium analyses of liquid samples.
Iodine on absorbers
"B" criteria are applied to the following analyses:
Gamma Spectrometry where principal gamma energy used for identification is less than 250 Kev.
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89Sr and 90Sr Determinations.
Gross Beta where samples are counted on the same date using the same reference nuclide.
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