IR 05000201/2024002
| ML24352A033 | |
| Person / Time | |
|---|---|
| Site: | West Valley Demonstration Project |
| Issue date: | 01/02/2025 |
| From: | Eve E Decommissioning, ISFSI, and Reactor Health Physics Branch |
| To: | Bower B US Dept of Energy (DOE) |
| References | |
| IR 2024002 | |
| Download: ML24352A033 (1) | |
Text
January 2, 2025
SUBJECT:
WEST VALLEY DEMONSTRATION PROJECT - U.S. NUCLEAR REGULATORY COMMISSION MONITORING VISIT REPORT NO.
Dear Bryan Bower:
On July 23 - 24, 2024 and November 19 - 20, 2024, the Nuclear Regulatory Commission (NRC) conducted announced monitoring visits at the U.S. Department of Energys West Valley Demonstration Project site to review ongoing decommissioning activities. The monitoring visits consisted of observations by the NRC representatives, a review of documents, interviews with site personnel and site walkdowns supplemented by in-office reviews and periodic phone calls.
The results of the monitoring visits were discussed with Jamie Prowse of your staff on December 9, 2024, and are provided in the enclosed report.
Based on the results of this monitoring period, no public health and safety issues of more than minor significance were identified.
No reply to this letter is required. Please contact Andrew Taverna of my staff at (610) 337-5119 if you have any questions regarding this matter.
Sincerely, Elise Eve, Team Leader Decommissioning Team Decommissioning, ISFSI, and Reactor Health Physics Branch Division of Radiological Safety and Security
Docket No.
05000201 License No. CSF-1
Enclosure:
Report No. 05000201/2024002 ELISE EVE Digitally signed by ELISE EVE Date: 2025.01.02 13:33:25-05'00'
EXECUTIVE SUMMARY
U.S. Department of Energy (DOE)
West Valley Demonstration Project (WVDP)
NRC Monitoring Visit Report No. 2024002
Announced monitoring visits were conducted on July 23 - 24 and November 19 - 20, 2024 by U.S. Nuclear Regulatory Commission (NRC) staff at the DOE WVDP site in West Valley, New York, supplemented by in-office reviews and periodic phone calls. The monitoring visits included reviews of programs and activities associated with the West Valley 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; walkdowns of the facility; and observations of in-progress work activities. The program for conducting NRC monitoring visits at the WVDP is described in Inspection Manual Chapter (IMC) 0111, Region I Monitoring Activities for the Department of Energy West Valley Demonstration Project.
Based on the results of this monitoring period, no public health and safety issues of more than minor significance were identified.
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, announced routine monitoring visits were conducted on July 23 - 24 and November 19 - 20, 2024 by NRC staff at the DOE WVDP site in West Valley, New York, supplemented by in-office reviews and periodic phone calls. The program for conducting NRC monitoring visits at the WVDP is described in IMC 0111. The monitoring visit included reviews of programs and activities associated with the WVDP site decommissioning project.
2.0 Main Plant Process Building (MPPB) Demolition
a.
Monitoring Visit Scope
The Main Plant Process Building (MPPB) was the main facility used for commercial nuclear fuel reprocessing; the MPPB was built between 1963 and 1966 and used by Nuclear Fuel Services from 1966 to 1972. The building consisted of a series of cells, aisles, and rooms that are mostly above grade with some extending below ground surface. Portions of the MPPB were modified over the past four decades by the WVDP to support mission activities such as solidifying high-level waste.
In September 2022, CH2M HILL BWXT West Valley, LLC (CHBWV) began the phase of its contracted work to demolish the MPPB to grade level (100 +/- 3 ft) safely. All below-grade structures were previously grouted with controlled low-strength material in preparation for demolition activities. Demolition was on track to be completed in the second quarter of 2025.
The on-site monitoring visits consisted of interviews with DOE staff and contractor personnel, including discussions with cognizant personnel on airborne radioactivity monitoring, groundwater monitoring, waste processing, protected assumption compliance, and radioactive waste shipping. NRC staff performed walk-downs of the site, including the perimeter of the MPPB demolition area, liquid waste processing systems, the remote handled waste facility, the radiological control room, the lag storage facility, and the radioactive waste shipping area The NRC staff observed ongoing MPPB demolition which included the PMC west wall and vit bay 18.
The NRC staff reviewed the Annual Site Environmental Report (ASER) for 2023 and discussed the results with CHBWV and DOE personnel.
The NRC staff reviewed field change 14 to DOEs MPPB Demolition Work Instruction Package (WIP), which added new demolition instructions for the Off-Gas Cell (OGC) as the planned demolition method was changed from quarry saw cutting to hydraulic hammering due to operational challenges with the quarry saw. The NRC reviewed updates to WVDP-606, Main Plant Process Building Radionuclide Inventory for 40 CFR 61 Subpart H and WVDP-607, Air Dispersion Modeling for Open Air Demolition, which reflected a decrease in the calculated material-at-risk in the OGC corner based on new characterization data from core bore sampling.
b. Observations and Findings
The Work Instruction Package (WIP) for MPPB demolition includes protected assumptions, which are specific conditions that ensure the demolition is conducted in a manner consistent with the assumptions made in the modeling of expected radiological consequences. Examples of protected assumptions are minimum duration of demolition for specific areas and the use of dust suppression. CHBWV implemented a program of tracking and enforcing protected assumption compliance, involving a daily checklist and multiple observers who monitor whether controls are being followed during work activities. The NRC monitors discussed this program and reviewed recent data with the responsible individual and noted that site compliance goals for protected assumptions were being met.
During site walkdowns, the NRC noted that the demolition activities observed were being conducted in accordance with the WIP and specifically noted improved dust suppression during demolition of the PMC west wall with the addition of another sprayer. The NRC found the waste storage facility and liquid waste processing systems to be in adequate material condition with no evidence of leakage to the environment. The NRC found waste shipping procedures to be adequate to ensure that DOT and waste facility requirements are met.
Airborne activity monitoring on site is provided by Environmental Continuous Air Monitors (ECAMs) and Fixed Air Samplers (FAS) around the perimeter of the demolition area. The ECAMs transmit near-real-time data to the control room, where activity levels are monitored against three escalating action levels. NRC staff found all 14 ECAMs operational and communicating with the control room at the time of the monitoring visits.
Offsite airborne activity monitoring is provided by sixteen low-volume ambient air samplers surrounding the site, one in each of the sixteen compass point sectors, used to demonstrate compliance with the EPA NESHAP dose limit of 10 mrem per year.
On June 10, WVDP experienced a level 2 alarm on one of the ECAMs during shearing of a Process Mechanical Cell vent pipe. The section of pipe was being size reduced for packaging in a waste container; however, dust suppression was inadequate, and contamination was spread on site downwind of the shearing location. Low levels of contamination were found outside of the sites posted Contaminated Area in the Radiological Buffer Area (RBA) and isolated contamination was found outside the RBA within the larger site Radiologically Controlled Area (RCA). Contamination outside the posted boundaries was removed or fixed. The NRC reviewed surveys to verify that the extent of contamination was evaluated, and results did not exceed regulatory limits.
Maximum potential on-site dose consequences from the release were minimal and airborne concentrations did not exceed the site average Derived Air Concentration (DAC) or DAC-hour limit at the RBA boundary. Personnel working in the inner demolition areas with higher potential for airborne exposure wear respirators and there were no internal exposures resulting from the release. CHBWV performed a review of the event, identified weaknesses for improvement and developed corrective actions which included additional safety requirements for high-risk items and management oversight. The NRC found the sites response to the incident to be appropriate and noted that low levels of radioactivity were detected offsite due to this event which resulted in a maximum sector dose of 0.015 mrem, or 0.15% of the 10 mrem annual limit, at monitor AF15.
On September 30, WVDP experienced a level 3 ECAM alarm during demolition of the Process Mechanical Cell ceiling when a large piece of concrete fell unexpectedly and impacted high-activity components and a debris pile. This resulted in an airborne release and spread of low levels of contamination on site. Access to the site was restricted while radiological control personnel thoroughly surveyed the impacted areas and contamination was remediated. The NRC staff reviewed survey results to verify that the extent of contamination was appropriately evaluated and that levels did not exceed DOE posting limits. On site airborne concentrations as a result of this event did not exceed DAC-hour or average DAC limits at the RBA boundary. CHBWV performed a review of the event and identified corrective actions including the need for additional controls for demolition of higher activity areas. Following this event, a filter from offsite air monitor AF14 was found to have detectable radioactivity and was sent to an offsite lab for analysis rather than being sent with a composite sample at the end of the quarter as is typical procedure. The analysis indicated positive detections of Cs-137, Sr-90, Am-241, Pu-238, and Pu-239, with a dose of 0.3 mrem, or 3% of the 10 mrem annual limit, at monitor AF14. An Unreviewed Safety Question Process screening determined that the consequences of the event did not exceed the drop during demo event previously evaluated in the Documented Safety
Analysis.
The NRC noted that while no protected assumptions in the work instruction package were violated in these events, more prescriptive work instructions such as work sequencing to remove high-activity components that could potentially be impacted by debris and specific requirements for dust suppression may have mitigated the releases.
The NRC observed that additional controls were in place at the time of the monitoring visits, such as additional dust suppression and restrictions on certain demolition activities based on wind direction.
The NRC verified that the change in planned demolition method for the OGC was not anticipated to significantly increase on-site air emissions, and that controls prescribed in the WIP for that activity were appropriate based on modeling assumptions. To reevaluate the Material-At-Risk (MAR) in the OGC corner, a series of core bores were drilled on either side of the construction joint between the Chemical Process Cell (CPC)and the OGC and dose rate surveys were performed at various distances within the core holes. MicroShield modeling was used to obtain a dose-to-activity conversion factor to estimate the total activity in the construction joint. This resulted in a significant reduction in the MAR compared to the original estimate which was based on an assumption of higher contamination levels throughout the area in question. The NRC found that the methodology used in the revised calculation was reasonable.
The radiological environmental monitoring program at the WVDP site measures 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 and that applicable regulatory requirements have been met. The most recent ASER for the WVDP documents the calendar 2023 environmental monitoring program data. Air and surface water pathways are the primary means by which radioactive material could potentially migrate 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.
Applicable radiological dose limits for the WVDP include U.S. Environmental Protection Agency (EPA) 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 EPA under the National Emission Standards for Hazardous Air Pollutants (NESHAP) regulation (Title 40 Code of Federal Regulations (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. In 2015, the EPA gave final approval for WVDPs use of ambient air monitoring data to demonstrate compliance with the NESHAP regulations and stack effluent measurements were no longer required. The results from sixteen low-volume ambient air samplers surrounding the site are used to demonstrate compliance with the NESHAP regulations. DOE Order 458.1 sets the DOE primary standard of 100 millirem/year effective dose equivalent for members of the public considering all exposure modes from DOE activities. For 2023, the ASER indicates that the estimated dose to a member of the public was 0.032 millirem from all WVDP sources. The airborne dose was 0.22% of the 10 millirem EPA limit and the total dose was 0.032% of the 100 millirem DOE limit. The ASER documented groundwater monitoring results continuing to show strontium-90 activity from the groundwater plume detected on site downgradient of the permeable treatment wall (PTW). WVDP continues to monitor groundwater and evaluate options for the future of the PTW.
c. Conclusions
No public health and safety issues of more than minor significance were identified.
4.0
Exit Meeting Summary
The NRC Region I representatives discussed the monitoring visit results with Jamie Prowse, DOE contractor, on December 9, 2024.
SUPPLEMENTARY INFORMATION
PARTIAL LIST OF DOCUMENTS REVIEWED
Work Instruction Package for MPPB Demolition, Field Change 11
Work Instruction Package for MPPB Demolition, Field Change 14
Process Mechanical Cell (PMC) Vent Pipe (15V960) Shearing Results in Spread of
Contamination-event summary and analysis document
WVDP Active Groundwater Monitoring Locations
WVDP Second Quarter 2024 Groundwater Monitoring Results
MPPB Demolition Air Monitoring Report, 2nd Quarter 2024
Ambient Air Concentrations Quarterly Update, Second Quarter 2024
Q1 2024 dose for Maximally Exposed Offsite Individual (MEOSI)
GEL Laboratories Certificate of Analysis for Q1 2024 offsite air monitoring positive detections
GEL Laboratories Certificate of Analysis for Q2 2024 offsite air monitoring positive detections
GEL Laboratories Certificate of Analysis for 10/1/2024 AF14 filter collection
Radiation and Contamination Survey Report Nos. 208059, 208063, 208975, 208979, 208980,
209009
Alpha spec report 2024-0174
Gamma spec report 2024-01776
WVDP-606, Revision 6, Main Plant Process Building Radionuclide Inventory for 40 CFR 61
Subpart H
WVDP-607, Revision 7, Air Dispersion Modeling for Open-Air Demolition
CALC-2024-003, Radiological Engineering Calculation, Determining Off Gas Cell Material-At-
Risk
Fact Finding Meeting Minutes FF2024-005, Rev. 1, Demolition of PMC Ceiling Results in Level
ECAM Alarm
USQS-24-078 Unreviewed Safety Question Process, Demolition of PMC Ceiling Results in
Level 3 ECAM Alarm
LIST OF ACRONYMS USED
Agencywide Documents Access and Management System
Annual Site Environmental Report
CHBWV
CH2M HILL BWXT West Valley, LLC
CFR
Code of Federal Regulations
Chemical Process Cell
Derived Air Concentration
Department of Energy
ECAM
Environmental Continuous Air Monitor
Environmental Protection Agency
FAS
Fixed Air Sampler
IMC
Inspection Manual Chapter
Material At Risk
Main Plant Process Building
NESHAP
National Emission Standards for Hazardous Air Pollutants
NRC
Nuclear Regulatory Commission
New York State Energy Research and Development Authority
Off-Gas Cell
PMC
Process Mechanical Cell
PTW
Permeable Treatment Wall
RBA
Radiological Buffer Area
Radiologically Controlled Area
WIP
Work Instruction Package
West Valley Demonstration Project