IR 05000201/1982001

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IE Insp Rept 50-201/82-01 on 820202-05.No Noncompliance Noted.Major Areas Inspected:Licensee Action on Previously Identified Enforcement Items & Followup on IE Info Notice 81-39
ML20042B685
Person / Time
Site: West Valley Demonstration Project
Issue date: 03/09/1982
From: Keimig R, Roth J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20042B681 List:
References
50-201-82-01, 50-201-82-1, NUDOCS 8203250528
Download: ML20042B685 (16)


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U. S. NUCLEAR REGULATORY COMMISSION Region I Re, port No. 50-201/82-01 Docket No. 50-201 License No. CSF-1 Priority

Category RP Licensee:

Nuclear Fuel Services, Incorporated 600 Executive Boulevard Rockville, Maryland 20352 Facility Name:

West Valley Reprocessing Plant

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Inspection At:

West Valley, New York Inspection Conducted:

February 2-5, 1982 8 k 2-Inspector-i J()toth,Proj t Inspector date signed Approved By:

eY M9/84 R.Keimig,Ch

, Projects Branch #2 da'te ' signed Summary:

Inspection on February 2-5, 1982 (Report No. 50-201/82-01)

Areas Inspected:

Routine unannounced inspection by a region-based inspector (33 hr.) of the licensed program including:

QA Program-Annual Review; organization; modifications and changes to facility and systems; internal review and audit; safety committees; procedure control; review of operations; nuclear criticality safety; review of limiting conditions for operation; transportation program; nonroutine events; licensee action on previously identified enforcement itcms; and followup on information notices.

Results: No Violations were identified.

8203250528 820310 gDRADOCK 05000201 PDR

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DETAILS 1.

Persons Contacted

  • J.P. Duckworth, General Manager / Plant Manager
  • P. Burn, Technical Services Manager
  • C.W. Alday, Operations Manager
  • R.T. Smokowski, Health and Safety Manager
  • C.E. Seitter, Quality Assurance Supervisor The inspector also contacted 14 other licensee employees.
  • present at the exit interview.

2.

Licensee Action on Previously Identified Enforcement Items (Closed) Inspector Follow Item (50-201/80-05-01) Examine licensee effluent analysis procedures to determine reasons for disagreement with NRC analysis results.

In Inspection Report 50-201/80-05, the comparison of the liquid effluent analysis (between licensee and NRC results) for samples split during inspection 50-201/78-06 were reported.

The licensee's in-house values were higher than the NRC values.

Since the licensee in-house values are used for release of liquid effluent from the site, this would not result in the licensee exceeding any.

technical specification liquid effluent release limits.

Since the licensee's values are conservative, and since there is an impending takeover of the site by a Department of Energy (D0E) contractor with a potential change in analytic technique, resolution of the disagreements would serve no useful purpose at this time.

Subsequent to the DOE takeover, additional samples will be taken and analytical results will be compared again.

(Closed) Violation (50-201/81-03-01) The backup person failed to sign a Radiation Work Permit (RWP).

The inspector determined that the backup person was available during the work conducted, however: he failed to sign the RWP.

The inspector verified that a notice was posted, to all employees, dated July 15, 1981, which reiterated the

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purpose, procedural requirements and importance of RWP's.

The facility safety training program during the month of August 1981 covered all aspects of RWP issuance and use.

Licensee records indicate that all required personnel took this training and completed a proficiency test in RWP requirements. Health and safety specialists were also retrained on RWP requirements and the licensee intitiated a weekly RWP review program to ensure that all RWP's are properly completed.

Corrective actions have been completed.

3.

Organization l

The inspector determined through discussions with licensee personnel and review of licensee records that there was only one change in the

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facility organization since inspection 50-201/81-01.

The Emission Specialist and Standards Supervisor, Mr. S.R. Greco, resigned from the facility effective December 11, 1981. Mr. Greco was also the designated facility Accountability Representative. Mr. L.W. Wiedemann was named

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the facility Accountability Representative and the laboratory supervision duties have been split between Mr. R.T. Smokowski, Health and Safety Manager and Mr. P. Burn, Technical Services Manager. Mr. L. Butler, who resigned as Process Cor. trol Laboratory Supevisor during October 1980, is still working as a consultant on a time plus material contract when needed to provide analytical services to the facility. No Violations were identified.

4.

Review of Operations The inspector examined all site areas to observe operations and activities in progress, to insp'ect the nuclear safety aspects of the facility, and to check the general state of cleanliness, housekeeping and adherence to fire protection rules, i

a.

Low Level Waste Treatment Facility The inspector observed that the two pressure gauges across the absolute filters on the two ventilation systems in the building were incorrectly identified.

Both systems (hot and cold) were identified on name plates as 479/400-401. According to facility drawings, the hot side should have been identified as 479/402 and the cold side as 479/401. Also, it was observed that the 0-30 inch pressure gauge on the inlet side of the 479/402 gauge was broken.

The licensee replaced the broken pressure gauge and properly identified the pressure gauges across the filters during this inspection. No Violations were identified.

b.

Warehouse During examination of the warehouse, the inspector noted that the fireload in the building had been reduced and that housekeeping appeared to be good.

No Violations were identified, c.

Fuel Receiving and Storage (FRS) Area The inspector noted that housekeeping in this area was good and that the Model NFS-4 cask and cask parts previously stored here had been shipped to the cask owner's facility. No Violations were identified.

d.

Log Books

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The inspector examined log books maintained in the waste tank farm (WTF) shelter, the low level waste treatment (LLWT) facility, and the Shift Supervisor's office. The WTF and LLWT log books

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for July 28, 1981 through February 3, 1982 contained entries indicating the time of day, date, shift, and individual taking instrument readings. The LLWT log indicated that the plant had been operated from July 28, 1981 through August 20, 1981, October 10, 1981 through November 4, 1981, and December 7, 1981 through December 29, 1981.

During this inspection, Lagoon 2 was about 60% full, indicating a need to startup the plant within two to three weeks, depending on the natural precipitation encountered.

These logs also indicated corrective actions taken when nonstandard conditions were observed (i.e. thawing of frozen pipes, etc.).

The Shift Supevisor's log for July 28, 1981 through November 30, 1981, included necessary instructions to subsequent shifts on a running commentary of conditions observed. No violations were identified.

e.

Operating Procedures The inspector compared the following operating procedures located in the Fuel Receiving and Storage Area (FRS) with those in the files in the control room and the Operation Manager's office.

50P I-8, Revision 9, dated April 1981, " Cask Unloading Crane" SOP I-9, Revision 8, dated April 1981, " Operation of Fuel Pool Canister Crane" S0P I-10 Revision 7, dated April 1981, " Operation of Fuel Pool Service Bridge and Fuel Hoist" SOP I-12, Revision 12, dated March 1981, " Fuel Pool Water System" SOP I-14, Revision 9, dated April 1981, "FRS Accountability" S0P I-16, Revision 6, dated April 1981, " Operation of the Cask Unloading Pool Lift Rack" S0P I-34, Revision 5, dated April 1981, " Operation of High Pressure Pump and Diesel Engine for FRS Cask Decon Stall" S0P I-35, Revision 11, dated July 1981, "FRS Filter Medium and Resin Disposal and Replacement" S0P I-36, Revision 6, dated October 1981, " Operation of the FRS Pool Cooling System" l

S0P I-38, Revision 5, dated March 1981, " Operation of the FRS Ventilation System" l

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SOP I-39, Revision 2, dated April 1981, "NFS-4 Spent Fuel Shipping Cask Handling Procedure" S0P 9-2, Revision 8, dated November 1981, " Solid Radioactive Waste Disposal" S0P 15-9, Revision 8, dated February 1981, " Process Building and FRS Exhaust Fans" S0P 15-14, Revision 8, dated November 1981, " Working in Contamination Zone 4 and High Radiation Areas" S0P 15-26, Revision 3, dated July 1981, " Work in Contamination Zone 3."

The inspector determined that the procedures in the FRS were the same revision and date as those in the files in the control room and in the Operations Manager's office as required by Technical Specification 7.1.3.

The inspector also examined at random, other procedures maintained in the control room and determined that these were also current revisions. No Violations were identified.

5.

Nuclear Criticality Safety a.

Laboratory Logs 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. Ear.h log was updated at least once each week as required by procedures. No Violations were identified.

b.

Radiation Monitors Selected radiation monitors throughout the facility were examined and appeared to be operating properly. The remote readout meters for each monitor are in the facility control room. All monitors were set to alarm at about 5 mR/hr except for the one on the north wall of the FRS which was set to alarm at 8 mR/hr. All remote meters located in the control room appeared to be operating properly. No Violations were identified.

6.

Facility Changes and Modifications The inspector determined, through discussions with licensee representatives and review of licensee records, that no significant facility changes or modifications had taken place since the last inspection. No Violations were identifie.

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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 14 Safety Committee meetings held from July 28, 1981 through January 13, 1982. The committee met at least at the required frequency. Quorum requirements for presence of three of the four voting members or their alternates were met in each case. According to the minutes, the topics discussed included review and approval of standard operating procedures, review of special procedures associated with the consolidation of poison rods, neutron source rods, and control rods into one canister located in the FRS fuel pool, and review of a contamination incident which occurred in

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the Coned Waste Tank Instrument Building on August 27, 1981. No Violations were identified.

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, 1981 through December 31, 1981. These audits cover Technical Specifications, 10CFR19, 10CFR20, 10CFR71, SNM-984, Security, and Special Nuclear Material Control requirements. The recorde showed that the following number of audits were conducted during the period reviewed.

Number of Audits Conducted Frequency Audits Performed Annual Requirement Monthly 492 492 Quarterly 240 240 Semi-Annual

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Total 777 777 Review indicated that all required audits were performed. No problem areas were identified during any of these audits performed by the Quality Assurance Supervisor. No Violations were identified.

9.

Nonroutine Events Coned Waste Tank Shelter Contamination Incident About 4 p.m. on August 27, 1981, the Coned waste tank shelter was contaminated to Zone 3 levels (in excess of 500 but less than 50,000

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8 dpm beta /100 cm ) during a housekeeping effort.

No alpha activity was observed.

The contamination source was determined to be about 3 millicuries of Sr-90 with some Cs-137. The activity was impregnated in a waste box and no radioactivity was released to unrestricted

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areas. The shelter was cleaned to less than 500 dpm beta /100 cm 2 within 4 days.

Contaminated materials were packaged for disposal as hot waste. No Violations were identified.

10.

Licensee Action on IE Information Notices The inspector determined through discussions with licensee representatives and review of licensee records that IE Information Notice 81-39 dated December 23, 1981 " EPA Crosscheck Program - Low Level Radioiodine in Water Intercomparison Study" had been reviewed for applicability. The licensee's documented review dated necember 31, 1981 indicated that there was no in-house capability to analyze effluents for I-131 and that I-131 analysis, when required, is conducted by a vendor laboratory.

Therefore, no useful purpose would be served by NFS participation in the crosscheck program. No Violations were identified.

11. Transportation Program a.

Shipping

The inspector examined standard operating procedure 50P I-39, Revision 2, dated April 1981, "NFS-4 Spent Fuel Shipping Cask Handling Procedure." This procedure covered all aspects of the preparation of a shipping cask for shipment from the site.

Attached to this procedure is a check sheet which details required information concerning the cask upon arrival at the site or prior to shipment from the site.

The inspector noted that the check sheet did not contain a dateline to indicate when the checks were completed.

For example, the preparation of the Model NFS-4 NAC-1C cask for shipment was started on or about September 21, 1981 and the cask did not leave the site until September 30, 1981. This was discussed at the exit interview.

The inspector verified that a special review of the shipment of the NAC-1C cask was conducted as required by the " engineer-in-charge" and by the Health and Safety Manager. The cask was prepared for shipment as required by S0P I-39 and the NFS-4 Check Sheet (Outgoing) was completed. The check sheet indicated that the routine tests required by 10CFR71.62 had been completed, that radiation surveys had been taken at the cask surface and at 3 feet, that the contamination levels on the cask were below regulatory limits, that the proper Radioactive Yellow II labels were affixed to the cask, that the bill of lading was properly completed and that the driver was given a set of Exclusive Use Instructions. No Violations were identified.

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b.

Transfer of a Radium-226 Source The licensee transferred a 10 millicurie Radium-226 check source,

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which was sealed in a stainless steel overpack and mounted in a lead pig, to a New York State licensed waste broker for disposal.

The licensee first attempted to transfer this source to the USEPA storage facility in Montgomery, Alabama.

Because of the size of the lead pig, this source could not be accomodated at the EPA storage facility and was transferred to the waste broker, F0B the licensee's site, on January 28, 1981.

It was packaged by the licensee in a specially designed 10 gallon D0T specification 6M container equipped with a 5 inch diameter specification 2R centered sleeve.

The shipment was received at the waste broker's facility on January 28, 1982.

Licensee records indicate that the shipment was properly labeled, and that the radiation and contamination levels on the shipping container met regulatory requirements. No

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Violations were identified.

12.

Quality Assurance Program

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The quality assurance program being implemented by the licensee is described in detail in the " Operations Manual for Quality Assurance,"

Revision 2, dated June 1980. The inspector examined that manual and determined that it incorporates, as required, the 18 criteria of 10CFR50 Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants." No Violations were identified.

13.

Limiting Conditions for Operation - Technical Specifications

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The inspector reviewed licensee records and discussed selected technical specifications with licensee representatives.

No Violations were identified.

a.

Technical Specifications 3.1.2 - Nuclear Fuel-Possession Limits 3.22-Source Material-Possession Limits 3.3-Calibration and Test Materials Inspector review of licensee records and discussions with licensee representatives verified that the licensee special nuclear material possessed on January 29, 1982 was within the applicable possession limits. No Violations were identified.

b.

Technical Specification 4.3-Storage Canister Loading and Spacing Through review of licensee records and visual examination, the inspector determined that canisters of irradiated fuel were loaded and the spacing between canisters was maintained as required.

A description of the contents of each canister was found to be as

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presented by the licensee in internal memos. No Violations were identified.

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Technical Specification 4.8-Uranium Product Solution Storage c.

The inspector determined through discussions with licensee re-presentatives and examination of licensee records that the Uranium

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Product Solution Storage Tanks SD-15A1 and 150-15A2 are each

filled to about 22% capacity with a total of 3,271 kilograms of depleted uranium containing a total of 8.105 kilograms U-235.

Uranium product weigh tank 5V-1 appeared to be empty as determined by sound tests and review of licensee records.

No Violations were identified.

d.

Technical Specification 4.12.1 - Excess Caustic Concentration in Carbon Steel Waste Tanks Licensee implementation of this Technical Specification was examined in detail during inspection 50-201/81-04. No significant additions of waste solutions have been made to these tanks since then. No Violations were identified, e.

Technical Siecification 4.13 - Radioactive Waste Burial The inspector verified that the licensee has been continuing to bury low level waste in strong tight containers in the NRC licensed burial ground, the location of which has been identified by concrete cairns on each corner of the burial site. The licensee is maintaining a map of burial trenches and holes and records indicating the contents of each trench and/or hole.

No Violations

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were identified, f.

Technical Specification 4.14-Exhaust Filter Differential Pressure The inspector determined through examination of operating strip chart recorders that the exhaust filter differential pressure across each filter is less than the maximum allowed (8.5 inches)

and is as follows:

Inches of Differential Location Filter Pressure Waste tank Off gas 8T1/1A 0.1 Head End 15T70, 71, 72, 73 0.8 15T73A 0.0 Vessel Off gas 6T2A.

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Dog-Vog Backup 6T3/3A 3.2 Main Building 15T49 2.5 Low level waste 479-401 (cold sida)

1.75 treatment 479-402 (hot side)

2.5 No Violations were identified.

g.

Technical Specification 5.3-Ventilation As indicated in subparagraph 13.f above, the licensee is maintaining the indicated ventilation systems operable. Alternate ventilation systems are available where required. The licensee is also maintaining a closed cycle ventilation system for the Fuel Receiving and Storage Area. No Violations were identified.

h.

Technical Specification 5.4-Spare Waste Tank Storage Capacity The inspector verified that the licensee is maintaining spare waste tanks in case of failure of one of the operating waste tanks. Tank 8D-1 is a spare for tank 8D-2 which is filled to about 80% of capacity with neutralized high level liquid waste.

Tank 8D-3 is a spare for tank 8D-4 which is filled to about 64%

of capacity with acidified high level liquid waste. The licensee has installed transfer equipment to facilitate the transfer of waste from tank 8D-2 to tank 80-1 if required.

Transfer equipment is available to facilitate transfer of waste from tank 80-4 to tank 8D-3.

No Violations were identified.

1.

Technical Specification 6.2.1-Sump Alarms and Eductors Licensee records indicated that the sump alarms and transfer ejuctors in the Products Purification 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 from April 7, 1981 through January 26, 1982.

No Violations were identified.

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Technical Specification 6.3.1-Waste Storage Tank Pan Instrumentation April 16,1981 through January 26, 1982 licensee records of periodic verification of operability of instrumentation for the presence of liquid in the 80-1 and 80-2 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 pans and vaults of the 80-1 and 80-2 tanks at least once each month. Operability of the level indicating and level alarm instruments for the 80-3 and 80-4 vault was also checked at least once each month during the same time perio.

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The records also indicated that immediate corrective actions were taken when required. No Violations were identified.

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Technical Specification 6.4-Emergency Utility Equipment k.

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 monnhs to determine the automatic start capability and performance under load.

Licensee records indicated that these tests had been conducted as required by Technical Specification 6.4.1 from April 16, 1980 through October 5, 1981.

According to licensee records, the boiler feed pumps (31G-2A and 31G-2B), 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 Specification 6.4.2 from August 11, 1980 through December 12, 1981.

Licensee records examined by the inspector from April 16, 1980 through February 1, 1982, indicated that the fuel in the diesel 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 April 1, 1980 through October 5, 1981 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 Specification 6.4.4.

The inspector verified that the licensee was maintaining at least 300 gallons of propane fuel in the propane fuel storage tank (150-3) as required by Technical Spec-ification 6.4.5.

No Violations were identified.

1.

Technical Specification 6.5-Air Filtration Equipment The inspector verified through examination of licensee records that each ventilation system had been tested to establish that the installed filters provide a collection efficiency of at least 99.95% for particulates 0.3 microns in diameter or larger, whenever the filters were changed or modified. Tabulated below are the results of these tests when the indicated filter was last changed.

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Ventilation System Filters Date Tested Test Results Dissolver Off gas 6T1 Out of service since 7/21/72 6TIA Out of service since 7/21/72

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Vessel Off gas 6T2 12/4/71 99.95%

6T2A 9/18/79 99.95%

Waste Tank Off gas 8T1 11/11/81 99.98%

8TIA 11/11/81 99.98%

Main Building 15T49 5/11/78 99.96%

15T49A 5/16/78 99.97%

D0G-V0G Backup 6T3 9/20/79 99.96%

6T3A 9/20/79 99.96%

Head End 15T72 8/4/72 99.98%

15T72A 8/24/72 99.99%

15T73 8/4/72 99.99%

15T73A 8/24/72 99.95%

Low Level Waste 479-402 9/18/74 99.98%

Treatment As indicated in subparagraph 13.f, the differential pressures across the final absolute filters are recorded by instrumentation.

In addition, the inspector verified that the recorders are equipped with alarms to annunciate high and low differential pressure on the final absolute filters as required.

No Violations were identified.

m.

Technical Specification 6.8-Blanking Off and Locking Out The inspector verified that the licensee has established procedures commensurate with the current operational status of the plant to assure that valves or pipes are locked out, disconnected or blanked off as required. When locked out or blanked off, a tag indicating the status of the affected valves or pipe is placed in a clearly visible location.

No Violations were identified.

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Technical Specification 6.9-Water Activity Alarms The inspector verified by review of licensee records that operability of radiation alarms monitoring return condensate or cooling water was tested at least twice each year between April 16, 1980 and February 5, 1982 by application of a radiation source to the system. No Violations were identified.

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Technical Specification 7.1-Administrative Requirements The inspector verified that the facility organizational structure included the positions described in the Technical Specifications, that the plant safety committee included the personnel required, and that these personnel met the minimum qualifications specified for members of the safety committee.

As described in paragraph 14, plant operating procedures, instructions and manuals were prepared and maintained as required.

In addition, it was verified that facility reviews and audits, emergency drills, and investigation of abnormal events were conducted as required.

No Violations were identified.

14. Procedure Control The description of the licensee's established and implemented system for control of procedures is given in the " Operations Manual for Quality Assurance." Section 5 of this manual, " Instructions, Procedures and Drawings," describes the different types of procedures and instructions used. These include:

Standard Operating Procedures (S0P's); Special Instruction Procedures (SIP's); Temporary Operating Procedures (TOP's);

Letters of Authorization (LOA's); Run Plans; and Radiological Protection Procedures. The Radiological Protection Procedures include the Health and Safety Manual, Safety Work Permits (SWP's), and Extended Radiation Work Permits (ERWP's).

Section 6 of the Quality Assurance Manual,

" Document Control," provides the control requirements for written procedures and instructions to define their issuance, distribution, retention, approval and changes made.

The Plant Safety Committee reviews and approves the following documents:

SIP's; SOP's; TOP's; LOA's; Emergency Procedures; Run Plans; and changes in process equipment design other than those permitted by previously approved procedures. Control of these procedures is provided from the time of submittal to the safety committee for review. Copies of procedures for review by the safety committee are submitted to the Operations Manager's secretary who assigns a number (SOP, TOP or LOA)

and a revision number if necessary. The secretary then indicates the type of revision or review to be conducted, records the identification number and ise date received in the Safety Committee Pending Log, and distributes a copy to each member of the committee.

The safety committee reviews, modifies, and approves the submittal. Approved procedures are returned to the Operations Manager's secretary who circulates the document for sign-off, notes the committee approval in the Pending Log, and distributes approved copies.

A master list of approved procedures is maintained in the Operations

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Manager's Office. A complete and current set of operational procedures

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is provided in the control room and in the Shift Supervisor's office.

Appropriate copies of procedures are also provided in the areas where the specific operations are performed. The Operations Manager holds

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assigned supervisors responsible for assuring that these areas are provided with the current applicable procedures.

During this inspection, the inspector selected 6 SOPS from one operating area and compared-them with the master files maintained in the Operations Manager's office ard in the control room.

It was determined that the procedures in each file were of the same revision as those in the operating area. Both master file sets of procedures were examined, found to be up-to-date, and appeared to be well organized.

The procedure control system for operating procedures appeared to be effective.

No Violations were identified.

15.

Facility Status Reports The licensee prepared a report dated June 12, 1981 " History of De-contamination-Nuclear Fuel Services, Inc. West Valley, New York" which presents a summary and history of the decontamination project which was initiated in 1972 "to reduce radiation and contamination levels in the various systems, and areas, to a point where the reliability and expansion projects could proceed with low radiation exposure to personnel."

The plant reliability and expansion projects were to be undertaken by the licensee to increase the capacity of the facility and to reduce radiation exposure to employees during subsequent operation.

Subsequent to the decontamination project, the licensee elected to shutdown the facility and to abandon the reliability and expansion projects.

The subject report presents information on the current status of each of the facilities and systems within the plant. The inspector ve,rified that several of the systems and facilities, selected on a random basis, were as described in the report.

The current status of several systems not described in this report is as follows:

a.

Laboratory Areas The licensee removed a contaminated drain line, a portion of the floor and a portion of the walls from underneath a fume hood in the hot laboratory to reduce background radiation. When completed, the background radiation was reduced from about 35 mR/hr to less than 5 mR/hr on contact. No Violations were identifie.

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Emergency Generating System The licensee maintains a 625 KVA diesel powered emergency generator with automatic start capability.

This generator supplies electrical power to selected lights, the WTF condensate pump, the WTF blowers, the V0G blowers, the WTF off gas blowers and cooling water re-circulating pumps in addition to other required units whenever off-site power is lost. No Violations were identified.

c.

High Level Waste Tank Corrosion Samples The inspector reviewed licensee records which indicated that corrosion coupons were removed from both the vapor space and the liquid space of tank 8D-2 during June 1976, analyzed, and reinstalled during August 1976.

The coupons were initially installed into the tank during April 1966. The tank was fabricated from type A-201 carbon steel with a 0.25 inch corrosion allowance.

Results of the corrosion coupon tests indicate that tank corrosion rate (maximum 0.00C53 inches / year) was considerably below the expected corrosion rate over the 10.2 year exposure period. The tank was initially designed for a minimum 50 year physical lifetine of active use.

Corrosion coupons were also removed from both the vapor space and the liquid space of tank 80-4 during May 1976, analyzed, and reinstalled during the same month. These coupons were initially installed into the tank during November 1968. This tank was fabricated from type 304L stainless steel with a 0.07 inch corrozian allowance. Results of the corrosion coupon tests indicate that the tank corrosion rate (maximum 0.000015 inches / year) was con-siderably below the expected corrosion rate over the 7.5 year exposure period.

The tank was initially designed for a minimum 50 year physical lifetime of active use.

No corrosion tests have been run on these coupons since May-June 1976.

No Violations were identified.

16. Consolidation of Burnable poison Rods The licensee prepared letters of authorization (LOA's) and special instruction procedures (SIP's) to provide the instructions to personnel for the consolidation of burnable poison rods from six fuel assemblies, 2 neutron source rod assemblies, and 1 control rod assembly into one fuel canister (#739) which was subsequently stored in position IB in the Fuel Storage Pool.

The following documents were examined by the inspector.

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LOA 204, Revision 2, dated November 11, 1981

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LOA 205, Revision 0, dated December 1, 1981

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SIP 81-36, Revision 1, dated November 11, 1981, " Remove Burnable

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Poison Rod Assemblies" SIP 81-38, Revision 1, dated December 2, 1981, "Dissassemble the

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RG&E Fuel Assembly Inserts" SIP 81-39, Revision 0, dated December 1, 1981, " Remove Additional

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Burnable Poison Rod Assembly."

The referenced LOA's authorized the movement of fuel bearing components in the fuel storage pool and the SIP's provided adequate step-by-step instructions as to how the work was to be accomplished and where each component was to be moved or stored. Adequate safety related instructions to workers were detailed in each procedure. No Violations were identified.

17. Discussions ~with DOE Representatives During this inspection, the inspector held informal discussions with U.S. Department of Energy (DOE), Idaho Operations Office personnel concerning the status of the facility and potential NRC Region I activities at the site after DOE takes over operation of the facility.

DOE takeover of the site as provided by the " West Valley Demonstration Project Act of,980" appears to be imminent.

18.

Exit Interview The inspector met with licensee representatives (denoted in paragraph 1) at the conclusion of the inspection about 1:15 p.m. on February 5, 1982. The inspector presented the scope and findings of the inspection and stated that no items of noncompliance were identified.