IR 05000201/2020001
| ML20041D726 | |
| Person / Time | |
|---|---|
| Site: | West Valley Demonstration Project |
| Issue date: | 02/10/2020 |
| From: | Anthony Dimitriadis Decommissioning Branch I |
| To: | Bower B West Valley Demonstration Project |
| References | |
| IR 2020001 | |
| Download: ML20041D726 (10) | |
Text
UNITED STATES ebruary 10, 2020
SUBJECT:
U. S. NUCLEAR REGULATORY COMMISSION MONITORING VISIT REPORT NO. 05000201/2020001, WEST VALLEY DEMONSTRATION PROJECT, WEST VALLEY, NEW YORK
Dear Mr. Bower:
On August 5 - 8, 2019 and January 14 - 15, 2020, the Nuclear Regulatory Commission (NRC)
conducted a monitoring visit at the U.S. Department of Energys West Valley Demonstration Project site to review ongoing decommissioning activities. The monitoring visit consisted of observations by the NRC representative, review of documents, and interviews with personnel.
The results of the monitoring visit were discussed with your staff on January 15, 2020, and are provided in the enclosed report. No public health and safety issues were identified.
No reply to this letter is required. Please contact Katherine Warner at (610) 337-5389 if you have any questions regarding this matter.
Sincerely,
/RA/
Anthony Dimitriadis, Chief Decommissioning, ISFSI, and Reactor HP Branch Division of Nuclear Materials Safety Docket No. 05000201 License No. CSF-1 Enclosure:
Report No. 05000201/2020001 cc w/Encl: Craig Rieman, Deputy Director Moira Maloney, Regulatory Strategy and Environmental Compliance Janice Williams, Regulatory Affairs Paul Bembia, Program Director
EXECUTIVE SUMMARY
U.S. Department of Energy (DOE)
West Valley Demonstration Project (WVDP)
NRC Monitoring Visit Report No. 2020001 Announced monitoring visits were conducted on August 5 - 8, 2019 and January 14 - 15, 2020 by United States Nuclear Regulatory Commission (NRC) staff at the DOE WVDP site in West Valley, New York. NRC staff also participated in the DOE quarterly public meeting on November 13, 2019 via telephone. The program for conducting NRC monitoring visits at the WVDP is described in Inspection Manual Chapter (IMC) 0111, Region I Monitoring Activities for the DOE West Valley Demonstration Project. The monitoring visit included a review of programs and activities associated with the WVDP site decommissioning project. The monitoring visits consisted of interviews with DOE, DOE contractors, and New York State Energy Research and Development Agency (NYSERDA) personnel; a review of documents; tours of the facility; observations of prepared work areas and in-progress work activities. Based on the results of these activities, no public health and safety issues were identified.
ii
REPORT DETAILS
1.0 Introduction In accordance with the WVDP Act of 1980 and as implemented by a Memorandum of Understanding between the DOE and the NRC, routine, announced monitoring visits were conducted on August 5 - 8, 2019 and January 14 - 15, 2020 by NRC staff at the DOE WVDP site in West Valley, New York. NRC staff also participated in the DOE quarterly public meeting on November 13, 2019. The program for conducting NRC monitoring visits at the WVDP is described in IMC 0111. The monitoring visits included a review of programs and activities associated with the WVDP site decommissioning project.
2.0 Annual Site Environmental Report
a. Inspection Scope
The NRC reviewed WVDPs Annual Site Environmental Report (ASER) for 2018 and discussed the report with DOE representatives and DOE contractor personnel.
b. Observations and Findings
The radiological environmental monitoring program at the WVDP site focuses on measuring radioactivity from site activities in air, surface water, groundwater, food products, soil, and sediment. Direct radiation is also measured through a network of thermoluminescent dosimeters (TLDs) on the site and around the site perimeter. The monitoring program provides information about the environmental radiological conditions at the site and is intended to verify that public health and safety and the environment are protected and that relevant regulatory requirements have been met. The most recent ASER (issued September 2019) for the WVDP documents the calendar year 2018 environmental monitoring program data. Air and surface water pathways are the primary means by which radioactive material could have the potential to migrate to areas off site.
The WVDPs on- and off-site monitoring program includes measuring the concentration of alpha and beta radioactivity in air and water effluents as well as specific radionuclide measurements in all environmental media.
Relevant radiological dose limits for the WVDP include U. S. Environmental Protection Agency (USEPA) regulations for air emissions and DOE limits regarding all exposure modes from DOE activities. Radiological air emissions (other than radon) from DOE facilities are regulated by the USEPA under the National Emission Standards for Hazardous Air Pollutants (NESHAP) regulation (40 CFR 61, Subpart H), which establishes a standard of 10 millirem/year effective dose equivalent to any member of the public (via the airborne pathway). DOE Order 458.1 sets the DOE primary standard of 100 millirem/year effective dose equivalent to members of the public considering all exposure modes from DOE activities. For 2018, information in the ASER indicates that the estimated dose to a member of the public was less than 0.6 millirem/year from all WVDP sources. The ASER continues to document elevated Strontium-90 (Sr-90)concentrations in groundwater and groundwater surface seeps from the area north of the Permeable Treatment Wall (PTW). The results from direct radiation measurements from off-site TLD perimeter locations were not significantly different compared to background levels.
As stated in previous reports, demolition of the vitrification facility began in September 2017 and was completed in September 2018, with the last off-site shipment of vitrification demolition waste completed in January 2019. As stated in the ASER, Cesium-137 was detected at three off-site air monitoring stations during the time period which the site was downsizing the vitrification shield doors via oxylance cutting. While the gross beta concentrations were higher than typical background values, the dose remained below the compliance limits.
c. Conclusions
No offsite public health and safety issues were identified. Calculated doses from radiological air and liquid effluents were well below EPA or DOE limits.
3.0 MPPB Deactivation
a. Inspection Scope
The NRC reviewed DOEs continuing progress for the deactivation of the Main Plant Process Building (MPPB) in preparation for eventual demolition, specifically the mock-up and operation of decontamination activities in Product Purification Cell - South (PPC-S).
The monitoring visit consisted of interviews with DOE staff and contractor personnel including discussions with cognizant personnel on the deactivation process, radiological operations, radiation protection, and radiological engineering. NRC staff performed observations of planned deactivation operations of PPC-S and of actual operations activities, as available.
b. Observations and Findings
WVDP continues deactivation of the MPPB in preparation for eventual demolition.
Additional deactivation work has been scoped into the current contract including work in the General Purpose Cell (GPC), Product Purification Cell-South (PPC-S), and the Fuel Receiving and Storage Facility. During the November 13, 2019 DOE quarterly public meeting, the DOE made a statement that the MPPB deactivation was approximately 98% complete.
As part of the deactivation work, DOE directed its contractor to reduce the material at risk (MAR) in PPC-S. Significant contamination on PPC-Ss surfaces under a difficult-to-remove fixative applied during previous decommissioning activities, combined with tight cell dimensions created numerous challenges for decontamination. In response to these challenges, the site conducted extensive mockup activities and is currently employing in-person use of Nitrocision equipment for aggressive decontamination to attempt to reduce the MAR down to levels where open-air demolition would be possible with normal means. The operation includes a worker standing on the in-cell mast climber while operating the Nitrocision wand contained in a secondary shroud over the surface to deactivate it by removing an appropriate depth of the wall. The secondary shroud is suspended from the top of the cell and braced to the wall prior to use.
During the August 5 - 8, 2019 monitoring visit, the NRC monitor conducted observations of the in-person decontamination mockup and held discussions with personnel on the challenges of the upcoming work. The NRC monitor noted that the site had successfully employed remote Nitrocision decontamination in head-end cells in the MPPB: (the Process Mechanical Cell and the GPC and applied lessons learned from those activities and the mockup activities to plan for in-person Nitrocision use). The extensive mockup activities allowed for many iterations of the Nitrocision system and associated ventilation to be tested and redesigned outside of contaminated areas. The monitor reviewed the ventilation system design to determine if there was adequate protection of the public during system operation. The monitor noted that a multistage ventilation system is employed to capture the MAR removed from the walls during Nitrocision activities. These mockup activities also allowed for operators to gain experience operating the equipment prior to in-cell operations. Key parameters that were tested during mockup activities include Nitrocision system pressure, operator speed, and depth of surface removed to determine the appropriate pressure and operator speed to strip away the majority of the contamination, while leaving relatively smooth walls for more effective or efficient future survey measurements.
During the January 14 - 15, 2020 monitoring visit, the NRC monitor conducted observations of the decontamination work and held discussions with personnel associated with the mockup activities that occurred since the August monitoring visit.
The discussions also included in-cell set up of the Nitrocision equipment and ventilation, and in-cell decontamination activities conducted thus far. The NRC monitor noted that the improvements made to the system since the August monitoring visit, including installation of a vacuum system for the secondary shroud, appeared to be appropriate and prudent thus providing additional protection to radiation workers. The NRC monitor attended the plan of the day meeting and the PPC-S pre-job brief on January 14, 2020. The NRC monitor noted that in-cell decontamination activities commenced on January 6, 2020 and several sections of wall had been successfully decontaminated. The NRC noted that DOE and its contractors appear to be appropriately focused on safety.
c. Conclusions
No public health and safety issues were identified. The NRC monitor will continue to review PPC-S decontamination activities during future visits.
4.0 Occurrence Reporting System
a. Inspection Scope
The NRC monitor reviewed selected occurrence reports and their associated corrective actions. The NRC monitor interviewed cognizant personnel, toured the affected areas, performed walk-downs, and reviewed documentation.
b. Observations and Findings
The NRC discussed several occurrence reports with cognizant personnel, including one report involving contamination discovered outside expected areas above DOEs internal reportable levels in April 2019. After relocating a waste container from an outdoor storage area, named Vit Corral, to another outdoor storage area named HIC Corral, workers discovered radiological contamination above reporting levels along the travel path and on the waste container and its supports. The area was secured, stabilized, and posted.
Additional contamination was later found in a nearby area called the Vit Vault and posted appropriately. The NRC notes that the occurrence reports indicate no airborne release as a result of these events. Discussions with DOE staff revealed that although in-leakage had not been found to be a problem, condensation had been identified as a concern when these containers were stored outdoors instead of indoors in a temperature-controlled environment. DOE and its contractors reviewed the extent of the condition and implemented corrective actions, including removal of the affected soil, setting the TRU waste container and other potentially degraded legacy waste boxes into pans, and installation of custom covers on containers. The NRC notes that the pans will be lifted with the containers to prevent recurrence.
c. Conclusions
The review of the event and associated corrective actions appeared to be thorough and appropriate. Corrective actions appeared comprehensive and timely.
5.0 Public Meetings DOE WVDP Quarterly Public Meetings NRC staff also participated in the DOE quarterly public meeting on November 13, 2019, via telephone and webinar. During the public meetings, DOE staff, DOE contractors, and NYSERDA representatives provided updates on the progress of various project milestones.
6.0
Exit Meeting Summary
The NRC Region I representative discussed the monitoring visit results with Jamie Prowse, DOE Contractor, on January 15, 2020. Mr. Prowse acknowledged the monitoring visit results.
SUPPLEMENTAL INFORMATION
PARTIAL LIST OF PERSONS CONTACTED
Department of Energy
- J. Dundas, Safety & Site Programs Team Leader
- J. Forti, Regulatory Strategies
- D. Gray, Facility Representative
- A. Kornak, General Engineer
- S. McCabe, Facility Representative
- A. Mellon, Project Manager
- B. Frank, Program Manager
CH2MHILL-B&W West Valley, LLC and Contractors
- R. Brown, Senior Radiation Protection Technician
- J. Capron, Senior Radiation Protection Technician
- D. Klenk, Regulatory Strategy
- M. Pendl, Regulatory Strategies
- A. Steiner, Senior Environmental Regulatory Strategist
- R. Steiner, Regulatory Specialist
PARTIAL LIST OF DOCUMENTS REVIEWED
2018 Annual Site Environmental Report Presentation, September 2019
CHBWV Safety Assessment Center Report, January 14, 2020
EM-OH-WVDP-CHBWV-WM-2019-0002, Relocation of a Legacy Waste Container Results in
Spread of Radiological Contamination, April 12, 2019
Monthly WVDP Project Performance Reports (various)
RWP#2020-3007, Execute PPC-South NITROCISION Decontamination Process and
Associated Activities, Effective January 1, 2020 - January 1, 2021
W1903655, Work Instruction Package Execute PPC-S Nitrocision Decontamination Process,
November 6, 2019
Weekly WVDP Project Status Reports (various)
WVDP Permeable Treatment Wall Update, October 23, 2019
LIST OF ACRONYMS USED
ASER Annual Site Environmental Report
DOE Department of Energy
GPC General Purpose Cell
IMC Inspection Manual Chapter
MAR Material At Risk
MPPB Main Plant Processing Building
NRC Nuclear Regulatory Commission
NYSERDA New York State Energy Research and Development Authority
PPC-S Product Purification Cell - South
TLD Thermoluminescent Dosimeter
USEPA U.S. Environmental Protection Agency
WVDP West Valley Demonstration Project
Enclosure